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CHARLES M. RUSSELL 

National Wildlife Refuge 

Montana 



MONTANA STATE LIBRARY 

S 639.95 U16cd 1984 c.2 

Draft environmental impact statement, ma 



3 0864 00050904 5 




United States Department of the Interior 

FISH AND WILDLIFE SERVICE 


MAILING ADDRESS: 

Post Office Box 25486 
Denver Federal Center 


STREET LOCATION: 

134 Union Blvd. 

Lakewood, Colorado 80228 


IN REPLY REFER TO: 


Denver, Colorado 80225 


February 23, 1984 


Dear Reader: 

Enclosed for your review and comment is a new Draft Environmental 
Impact Statement on the management of the Charles M. Russell National 
Wildlife Refuge in Montana. 

During August 1980, a Draft Environmental Impact Statement (DEIS) was 
printed and distributed for comment. Public meetings regarding the DEIS 
subsequently were held in Washington, D.C., and Lewistown, Glasgow, and 
Missoula, Montana. Litigation entered into in June 1981 interrupted this 
process, and publication of the Final EIS was delayed. 

Because of a delay of over 3 years, the earlier DEIS has been canceled, 
and this new DEIS has been prepared and is being circulated for comment. 
Comments, verbal and written, received during public review of the 
earlier DEIS have been incorporated into this document. 

The Proposed Action is an improved management program for the 1,094,301- 
acre refuge. Five alternatives are discussed: 1) continuation of the 

present management program (No Action), 2) enhanced wildlife habitat 
management (Proposed Action), 3) intensive wildlife management, 4) 
multiple use, and 5) elimination of livestock. 

Comments on this DEIS are hereby solicited and will be accepted until 
May 15, 1984, or 60 days after distribution of this document, whichever 
date is later. Written comments should be sent to: 


Regional Director (WR) 

U.S. Fish and Wildlife Service 
P.0. Box 25486, Denver Federal Center 
Denver, CO 80225 


Sincerely 


^Regional Director 



Enclosure 


DRAFT ENVIRONMENTAL IMPACT STATEMENT 


MANAGEMENT OF CHARLES M. RUSSELL NATIONAL WILDLIFE REFUGE 


Department of the Interior 

U.S. Fish and Wildlife Service 
Regional Office, Denver, Colorado 


February 1984 


Digitized by the Internet Archive 

in 2016 


https://archive.org/details/draftenvironment1984usfi 


FOREWORD 


i 

Historically, management of the Charles M. Russell National Wildlife 
Refuge (CMR) has been hampered by a lack of comprehensive planning and 
conflicting jurisdiction by three agencies: Army Corps of Engineers 

(COE), Bureau of Land Management (BLM), and U.S. Fish and Wildlife 
Service (FWS). 

Passage of Public Law 94-223 in 1976 resolved the jurisdictional 
problems with BLM. A Memorandum of Agreement in 1979 between COE and 
FWS solved most problems between these agencies. 

Public Law 94-223, dated February 27, 1976, also specifically directed 
that CMR would be managed under the National Wildlife Refuge System 
Administration Act of 1966. The recent decision of the Appellate Court 
reaffirmed this law. 

On September 20, 1979, the Fish and Wildlife Service issued a Notice of 
Intent (NOI) to prepare an Environmental Impact Statement (EIS) on the 
management of the CMR. 

The Service's scoping process provided opportunity for public input on 
the development of an EIS. Various groups and individuals from a wide 
variety of backgrounds and interests, which included Refuge permittees, 
did provide management recommendations. Public meetings were advertised 
by news media and phone calls. Letters were sent to individuals, 
Federal, State, and local government representatives, and other 
interested parties. Meetings were held by FWS in Lewistown, Helena, 
Billings, and Glasgow, Montana, in April 1978, and in Lewistown, Helena, 
Billings, Glasgow, Missoula, Jordan, Great Falls, and Glendive in 
September 1979. Corps of Engineers also held meetings at Glasgow, 
Lewistown, Glendive, and Jordan in June 1979. These efforts resulted in 
identification of specific resource problems and possible solutions. 

During August 1980, a Draft EIS (DEIS) was printed and distributed to 
interested parties for comment. Public meetings regarding the DEIS were 
held in Washington, D.C. and Lewistown, Glasgow, and Missoula, Montana, 
during late 1980. Public comments were solicited and received. 

Publication of the Final EIS was delayed due to court action (Schwenke, 
et al, vs. Secretary of the Interior, et al). On January 14, 1982, U.S. 
District Court in Billings, Montana, ruled: 

"....We have decided that the ranchers are entitled to have 
grazing declared a co-equal priority with wildlife 
conservation. ..." 

"....thus we must conclude that CMR must still be administered 
under the Taylor Grazing act." 


i 


The District Court's decision was appealed to the United States Ninth 
Circuit Court of Appeals. On October 14, 1983, the Appellate Court 
overturned the District Court and ruled that: 

"(1) Wildlife has priority in access to the forage resources of the 
range up to the limits specified in Executive Order 7509; 

(2) Beyond those limits, wildlife and livestock have equal priority 
in access to the resources of the Range; and 

(3) The Range is to be administered under the Wildlife Refuge Act." 

("Range" refers to the CMR. The "Wildlife Refuge Act" refers to the 
National Wildlife Refuge System Administration Act of 1966.) 

The ruling of the Appellate Court reaffirmed the criteria followed in 
preparing the original DEIS. However, due to a delay of over 3 years, 
the Service has decided to cancel the earlier DEIS and this new DEIS has 
now been prepared. 

All previous letters, verbal and written comments, and suggestions 
received during the earlier review process and public meetings have been 
addressed in preparation of the new DEIS. 

The new DEIS, while assessing various options proposed to resolve some 
of the Refuge's resource conflicts, is not a comprehensive management 
plan. 

Because habitat is recognized as the key to wildlife abundance, this 
document emphasizes habitat quality and quantity rather than wildlife 
populations or densities. Where possible, the habitat's capability to 
support numbers of animals per unit area has been used. Establishment 
of high quality wildlife habitat will provide desired populations of 
wildlife species within constraints imposed by drought, severe winters, 
disease, and other variables which are largely uncontrollable. 

Range conditions and wildlife habitat are not the same and should not be 
used synonymously. Range condition measures such parameters as plant 
species composition and production. It does not address important 
wildlife habitat components such as residual cover, vegetative 
interspersion and diversity, nor does it attach sufficient importance to 
key wildlife shrub communities. 

This Environmental Impact Statement follows the Council on Environmental 
Quality's regulations for implementing The National Environmental Policy 
Act, as amended July 30, 1979. Appendices, a glossary, and an index are 
in the back of the publication. A large, fold-out map is provided 
inside the back cover for easy reference. 


ii 


After public review of this DEIS, a Final EIS and Record of Decision 
(ROD) will be issued. This ROD will state which alternative has been 
selected for implementation. 

Once the Record of Decision is completed, specific habitat (allotment) 
management plans to meet the goals and objectives, as outlined in the 
Final Environment Impact Statement or as modified by the Record of 
Decision, will be developed. 

Management planning will be coordinated with BLM and affected publics. 
Management options such as fencing, range improvements, seasons of 
grazing use, etc. will be developed to meet Refuge objectives, while 
taking the needs of grazing permittees, land managing agencies, and 
other interested parties into full account. 

The National Wildlife Refuge System Manual will provide policy guidance 
for the issuance of grazing permits. In 6 RM 9.7 C(l) of the Refuge 
Manual, it states: "At CMR only, the purchaser of a current grazing 

permittee's private lands, unless ineligible for grazing privileges for 
reasons of age or citizenship, will be given preference for grazing 
privileges on the current permittee's allotment in the first ensuing 
grazing period." 

Further, 6 RM 9.9 of the Refuge Manual states, "Permits will normally be 
issued for a one-year period. Use of multi-year permits for special 
circumstances and unit rotations (up to a maximum of five years) must be 
provided for in an approved grassland management plan." Thus, one year 
grazing permits will continue to be issued until the AUM levels estab- 
lished by the Record of Decision are attained and habitat management 
plans are approved. Once this occurs, grazing permits of up to 5 years 
in length may be issued. 

Evaluation procedures will be included in the plans to ensure that the 
wildlife objectives are being achieved. 


iii 


CONTENTS 


Foreword i 

Contents iv 

Tables v 

Figures vii 

Appendices viii 

Summary x 

I. PURPOSE AND NEED FOR ACTION 1 

II . ALTERNATIVES 3 

Alternative A (No Action) 7 

Alternative B (Proposed Action) 9 

Alternative C (Intensive Wildlife Management) 18 

Alternative D (Multiple Use) 21 

Alternative E (No Grazing) 23 

Comparison of Alternatives 25 

III. AFFECTED ENVIRONMENT 32 

IV. ENVIRONMENTAL CONSEQUENCES 63 

Alternative A (No Action) 64 

Alternative B (Proposed Action) 71 

Alternative C (Intensive Wildlife Management) 81 

Alternative D (Multiple Use) 89 

Alternative E (No Grazing) 97 

V. LIST OF PREPARERS AND REFERENCES 104 

VI. CONSULTATION AND COORDINATION 124 

VII. APPENDICES 127 

VIII. GLOSSARY 232 

IX. INDEX FOR TEXT 236 

X. PUBLIC COMMENTS AND FWS RESPONSES 241 

REFERENCE MAP (Figure 10.) 345 


iv 


TABLES 


1. Summary comparison of effects of implementing 
various management alternatives on Charles M. 

Russell National Wildlife Refuge, Montana. 27 

la. Direct plus indirect impacts of change in livestock 

production on sales and employment. 28 

2. Direct plus indirect impacts in tourist visits on 

sales and employment. 29 

3. Total impacts of change in livestock production and 

tourism. 30 

3a. Comparison of direct effect on CMR ranchers. 30 

4. Land and water acreages within the Charles M. 

Russell National Wildlife Refuge, Montana. 32 

5. Major documents affecting the Charles M. Russell 

National Wildlife Refuge, Montana. 33 

6 . Groundwater sources on Charles M. Russell National 

Wildlife Refuge, Montana. 39 

7. Competing recreation resources on and within 150 miles of 

Charles M. Russell National Wildlife Refuge, Montana. 52 

8 . Estimates of current visitation on Charles M. Russell 

National Wildlife Refuge, Montana. 54 

9. Farm income data for a six-county region at Charles M. 

Russell National Wildlife Refuge, Montana. 57 

10. Comparative 1974 per capita income for a six-county 

region at Charles M. Russell National Wildlife Refuge, 57 

Montana . 

10a. Charles M. Russell National Wildlife Refuge study region 
and the Montana economy (Fergus, Garfield, McCone, 

Petroleum, Phillips, and Valley counties, Montana.) 58 

11. Demographic data for counties contiguous to Charles M. 

Russell National Wildlife Refuge, Montana. 60 

12. Noneconomic effects, No Action alternative, Charles M. 

Russell National Wildlife Refuge, Montana. 70 


v 


TABLES (continued) 


13. Noneconomic effects. Proposed Action alternative, 

Charles M. Russell National Wildlife Refuge, Montana. 80 

14. Noneconomic effects. Intensive Wildlife Management 

alternative, Charles M. Russell National Wildlife 88 

Refuge, Montana. 

15. Noneconomic effects, Multiple Use alternative, 

Charles M. Russell National Wildlife Refuge, Montana. 96 

16. Noneconomic effects. No Grazing alternative, Charles M. 

Russell National Wildlife Refuge, Montana. 102 

17. Agencies and organizations which provided comments on 

the Environment Impact Statement, Management of Charles M. 
Russell National Wildlife Refuge, Montana. 124 


vi 


FIGURES 


1. Recreation proposals, Charles M. Russell National 

Wildlife Refuge, Montana. 15 

2. Vegetation types, Charles M. Russell National Wildlife 

Refuge, Montana. 41 

3. Mule deer and white-tailed deer habitat, Charles M. 

Russell National Wildlife Refuge, Montana. 44 

4. Elk and sharp-tailed grouse habitat, Charles M. 

Russell National Wildlife Refuge, Montana. 47 

5. Pronghorn and sage grouse habitat, Charles M. Russell 

National Wildlife Refuge, Montana. 48 

6. Bighorn sheep habitat, Charles M. Russell National 

Wildlife Refuge, Montana. 49 

7. Prairie dog towns, Charles M. Russell National 

Wildlife Refuge, Montana. 50 

8. Existing recreation resources, Charles M. Russell 

National Wildlife Refuge, Montana. 55 

9. Grazing allotments, Charles M. Russell National 

Wildlife Refuge, Montana. 61 

10. Reference Map, Charles M. Russell National Wildlife 

Refuge, Montana. 345 


vii 


APPENDICES 


1. Section 7 Evaluation, Charles M. Russell National 

Wildlife Refuge, Montana. 127 

la. Section 7 Intra-service consultation results. 133 

lb. The Planning Process for the CMR National Wildlife Refuge EIS. 135 

2. Habitat evaluation procedures and values on Charles M. 

Russell National Wildlife Refuge, Montana. 137 

3. Memorandum of Agreement between District Engineer, 

Omaha District, Corps of Engineers and Area Manager, 

Billings Area Office, Fish and Wildlife Service for 
the Charles M. Russell National Wildlife Refuge and 

Fort Peck Lake Project, Montana. 158 

4. Executive Order 7509 establishing the Fort Peck Game 

Range, Montana. 159 

5. Federal stocking levels in AUMs under each management 
alternative (livestock) for the Charles M. Russell 

National Wildlife Refuge, Montana. 161 

6. Public Law 94-223, 94th Congress, H. R. 5512, 

February 27, 1976. 164 

7. Soils limitations and capability classes, Charles M. 

Russell National Wildlife Refuge, Montana. 166 

8. Range survey methodology and productivity, Charles M. 

Russell National Wildlife Refuge, Montana. 171 

9. Range condition class by breakdown by livestock operator 

and allotment on the Charles M. Russell National Wildlife 
Refuge, Montana. 179 

10. Direct economic impacts of changes in livestock forage 
supplies - livestock businesses that use the Charles M. 

Russell refuge. 183 

11. Income in the six-county region at Charles M. Russell 

National Wildlife Refuge, Montana, 1960 and 1970. 204 

12. Number of persons 14 years or older employed in the six- 
county region of Charles M. Russell National Wildlife 

Refuge, Montana, 1960 and 1970. 205 

13. Estimation of indirect economic impacts. 206 


viii 


APPENDICES (cont'd) 


14. Summary comparison of important wildlife habitat 

conditions for the present situation and five management 
alternatives on the Charles M. Russell National Wildlife 


Refuge, Montana. 214 

15. Methodology employed in calculation of AUMs on 

Charles M. Russell National Wildlife Refuge, Montana. 216 

16. Literature review for Charles M. Russell National 

Wildlife Refuge, Montana, range survey and wildlife- 
livestock interrelationships. 222 

17. Methodology for estimating visitor use on the Charles M. 

Russell National Wildlife Refuge, Montana. 229 


ix 


SUMMARY 


This Environmental Impact Statement (EIS) is prepared in specific 
response to litigation filed in U.S. District Court for the District of 
Columbia, entitled Natural Resources Defense Council , Inc. , et al . 
versus Rogers C. JB. Morton , et al. (June 1975). The EIS presents five 
management alternatives to solve some of the resource problems on 
Charles M. Russell National Wildlife Refuge (CMR) , located in north- 
eastern Montana. 

Nearly 1.1 million acres comprise CMR which includes the 249,000-acre 
Fort Peck Reservoir. Part of the Missouri River which flows through 
the refuge is administered by the Bureau of Land Management as the 
nationally designated Upper Missouri National Wild and Scenic River. 

Besides the grazing activity authorized by the Executive Order establishing 
CMR, three state parks managed by the Montana Department of Fish, Wildlife 
and Parks and several recreation areas administered by the Army Corps 
of Engineers (COE) are located on the refuge, making this an atypical 
refuge compared to other units of the National Wildife Refuge System. 

Although varying quantities of oil, gas, and coal are known to occur 
beneath the rugged landscape, these and other energy resources have a 
low to moderate potential for development. However, development of 
these resources outside the refuge and in the surrounding region could 
increase significantly in the future and would have far-reaching impacts 
on the refuge. 

Soils on the refuge fall into four major orders: Mollisols, which 

are highly productive prairie soils and are quite limited; Aridisols, 
which possess potential for agricultural use; Entisols, which typically 
are found in the "breaks" portion of the refuge and have a very unstable 
surface; and Vertisols, which are commonly associated with fine textured 
Bearpaw shales found on strongly sloping sedimentary uplands. Soils and 
weathered bedrock on the refuge are moderately to highly expansive, 
tending to swell when wetted and heave when excavated which limits the 
types of development they can support. 

Five major vegetative types exist on the refuge, the largest being 
the sagebrush-greasewood-grassland type that comprises more than 60 
percent of the area. About 35 percent of the area is associated with 
the ponderosa pine-juniper type. Grassland, riparian, and cultivated 
land types occupy the balance of the area. Although the riparian 
community was extensive before being inundated by Fort Peck Reservoir, 
it now occupies only 0.7 percent of the area and provides one of the most 
important and productive wildlife habitat types. 

Warm summers and cold winters create a harsh environment. From the 
uplands to the flood plains, the great variation in topography and 
vegetation creates a diversity of wildlife habitat. Plains grizzly 
bears, American bison, Audubon bighorn sheep and wolves once roamed the 
refuge, but are no longer present. Even before their time, the area 
supported a rich assemblage of plant and animal life, as evidenced by 
significant paleontological discoveries in the Hell Creek and Fort Union 
formations . 


x 


Summary 


Today the primary species are mule deer, white-tailed deer, prong- 
horns, Rocky Mountain elk, sharp-tailed and sage grouse and black-tailed 
prairie dogs. No threatened species of animals are known to occur on 
the refuge. Endangered wildlife species include peregrine falcons, bald 
eagles and possibly black-footed ferrets. The refuge may be within the 
geographical distribution of Rorippa calycina , a species of watercress 
which is proposed for classification as a threatened plant species. 

Wildlife habitat on the refuge is only in fair condition. Present 
deficiencies in habitat include lack of residual cover (grasses and 
forbs) on upland sites, around ponds and in hardwood draws, poor quality 
and small quantity of deciduous shrubs and trees in hardwood draws and 
along minor stream courses, poor quality sagebrush stands and insuf- 
ficient timber density in some areas. There is potential to improve 
most of the habitat on CMR. 

In terms of climax range vegetation, the refuge is predominantly in 
good condition. Where deteriorated conditions are present, poor live- 
stock distribution is the most common problem, causing about seven 
percent of the grazed portions of the refuge to be in fair range con- 
dition. Portions of the refuge in poor range condition are generally 
associated with prairie dog towns or flood plains. 

The refuge has relatively few developed recreation areas. Most of 
these are COE areas located near Fort Peck Townsite and the Big Dry Arm 
segment of the reservoir. Private cabins are located on federal land at 
four locations. Including visitation at COE and state facilities, an 
estimated 357,000 visitor days of use occurred on the refuge in 1978. 

The most popular activities were viewing scenery and exhibits, picnicking, 
hunting, fishing, powerboating, and camping. Most of this use occurred near 
developed recreation areas on the east side of the refuge. 

Numerous prehistoric campsites, tipi rings, stone markers, bison 
kill sites, homesteads, pioneer graves and townsites are scattered 
throughout the area. There is one designated national historic site, 
two national natural landmarks, four research natural areas, one desig- 
nated wilderness area, 15 proposed wilderness areas and the Upper 
Missouri National Wild and Scenic River. 

Grazing and haying activities on the refuge, contribute slightly 
to the Regional economy. Expenditures by recreationists generate 
additional income, as does hydropower production from Fort Peck Dam and 
Reservoir. The area around the refuge has been characterized by rela- 
tively slow economic growth with an economy based on the production of 
grain and livestock. 

In 1979 there were 67 grazing allotments located partially or 
totally on the refuge, consisting of 87 individuals, companies or 
associations grazing about 60,000 animal-unit months (AUMs) . Based on 
a grazing fee of $1.89/AUM, this activity contributes nearly $107,000 to 
the US Treasury. Since 1979, trending the issuance of an EIS , the Refuge 
has essentially been managed on a status quo basis. One exception is that 
grazing fees have increased. In 1984, grazing fees were $4.61/AUM, thus 
contributing about $277,000 to the U.S. Treasury. 


xi 


Summary 


Approximately 800 acres of land were farmed on the Refuge by eight 
cooperators. Income derived from this source was estimated to be less 
than $10,000. 

Appendix lb. delineates the planning process for CMR. 

Summaries of five alternatives considered in this document and their 
probable impacts are: 

NO ACTION ALTERNATIVE 


Management would continue unchanged. Animal damage control 
would occur to solve specific problems. Livestock numbers would not 
change. Major management actions would include surveys, issuing grazing 
licenses, some cooperative farming and wildfire control. There would be 
no significant improvement in range conditions or wildlife habitat. Any 
changes in the status of recreational development would be accomplished 
in accordance with the Memorandum of Agreement of July 1979 and in 
accordance with FWS policies and objectives. 

PROPOSED ACTION ALTERNATIVE 


Peregrine falcons, black-footed ferrets, bighorn sheep and swift 
fox would be reintroduced as they become available. Wildlife habitat 
conditions would be substantially enhanced by 2005 with most grazing 
reductions and other major actions implemented by 1990 and the remainder 
by 2005. Wildlife habitat management objectives would be met or exceeded 
refuge-wide by 2005 . Significant management actions would include adoption 
of prescription grazing that would result in reduction in livestock grazing 
as well as changing existing livestock seasons of use and modifying exist- 
ing grazing systems to benefit wildlife. Some shrub planting and construc- 
tion of exclosures would occur. Most wildfires would be suppressed and 
some prescribed burning would occur on the west half of the refuge and in 
Garfield County. Some boundary fences and a few interior fences would be 
constructed. A few new reservoirs, water pipelines and several troughs 
would be built. Wildlife habitat would be evaluated periodically to ensure 
that wildlife objectives were being met; necessary corrections in manage- 
ment would be made. Farming along the Missouri River would be phased out 
but some lure crop farming would be tried to decrease elk depredation on 
private lands. Animal damage control would be similar to the No Action 
alternative . 

Federal livestock AUM's would eventually be reduced an average of 
33 percent below levels presently authorized to achieve a light grazing level 
determined to be consistent with wildlife objectives. Some inholdings would 
be acquired and ownership of all lands within CMR would be ascertained. 

There would be more opportunities for wildlife recreation due to 
improvement of habitat and expected increases in wildlife populations. 

Present high and low density recreation areas would be retained and ex- 
panded as needs dictate. A new boat access site would be established at 
Fourchette Bay. Private cabin sites would not be affected at the time. 
Interpretive programs would be emphasized and access to recreational areas 
and facilities would be improved. 


xii 


Summary 


INTENSIVE WILDLIFE MANAGEMENT ALTERNATIVE 


Special arrangements with the State Land Board (SLB) and COE changes 
in policy for CMR would have to occur to fully implement this alternative. 

A substantial budget increase would be necessary. 

Endangered and unique species introductions would be as stated in 
the Proposed Action alternative. About 2,000 acres would be farmed in plots 
of varying sizes to increase wildlife food supplies and habitat diversity. 
Waterfowl ponds would be developed at UL Bend. Bison would be introduced 
on the UL Bend area. Spawning habitat for fish would be developed on the 
reservoir. Wildlife habitats would be enhanced to maximum potential for 
most species in a minimum time span. Most actions to achieve desired habitat 
levels would be implemented by 1990 and the remainder by the year 2005 ; how- 
ever, the time required for maturation of certain vegetative communities 
would take 50 or more years. Burning, farming, soil ripping, shrub and 
conifer planting and exclosure fencing would be considerably more extensive 
than the Proposed Action. Periodic habitat evaluation would occur and most 
wildfires on CMR would be suppressed as stated in the Proposed Action. Some 
prescribed burning would occur in Garfield County and on the west half of the 
refuge. Many inholdings would be acquired. Predator control to protect 
livestock and prairie dog control would be the same as the No Action alter- 
native. Coyote and small mammal control to benefit other wildlife species 
would be minimal. The naturalness management concept would be eliminated in 
favor of developments which would provide maximum benefits to wildlife. 

Livestock grazing would be employed as a tool to achieve or maintain 
desired wildlife habitat. Livestock AUMs would be reduced to about 27,000- 
30,000 federal AUMs as a result of this alternative. 

Range improvements would be limited to fencing approximately two-thirds 
of the refuge boundary to regulate livestock. 

Recreation would be oriented toward wildlife activities. Private cabins 
would be eliminated and the areas returned to wildlife habitat. More primi- 
tive fishing access sites would be provided and replace some existing high 
and low desity recreation areas. Nature trails would be established at 
several locations. 

MULTIPLE USE ALTERNATIVE 


This alternative would require Congressional action to implement. It 
would emphasize all resources instead of just wildlife. Wildlife values 
would be equal to livestock as would recreation. This alternative would 
provide only slight improvements in habitat quality and wildlife objectives 
would not be met by the year 2005. About 41,000 acres would be improved 
for wildlife habitat by prescribed burning, soil ripping, shrub planting 
and farming. Ten miles of exclosure fence would be constructed. Most 
wildfires would be controlled as soon as possible. 

Animal damage control for livestock losses would be conducted under 
the same regulations as adjacent land. Animal damage control for wildlife 
other than coyotes would be minimal. Waterfowl production areas would be 
expanded at UL Bend. Endangered and unique species introductions would be 
more limited than the Proposed Action alternative. 


xiii 


Summary 


Livestock would receive approximately one-half the allocated forage by 
the year 2005. There would be some boundary and interior fence construction. 
Seventy-seven reservoirs, two springs and 13 water troughs would be con- 
structed, and deferred or rest-rotation grazing systems would be implemented 
on twelve allotments. 

Recreational use and development would be greater than with the 
other alternatives. As needs dictate, high and low density recreation 
areas would be expanded, a perimeter shoreline scenic road in the vicin- 
ity of Fort Peck would be constructed and a major backcountry trail 
extending the length of the refuge would be designated. Private cabins 
would remain as they are. 

NO GRAZING ALTERNATIVE 


Changes in SLB policy would have to occur before state inholdings 
could be acquired. All private and state inholdings would have to be 
acquired before elimination of livestock grazing could occur since most 
of these areas are unfenced and stocked by the operators at carrying 
capacity levels. Habitat improvements in residual cover and quantity of 
forbs would be maximized. Increased shrub quality in hardwood draws 
would be significant. About 28,500 acres of habitat would be improved 
by farming, prescribed burning, soil ripping and shrub and conifer 
planting. Six miles of exclosure fence would be constructed. Wildfire 
control would be similar to the Proposed Action. 

Animal damage control for wildlife and livestock would be the same 
as the No Action alternative. Endangered and unique species introduc- 
tions would be similar to the Proposed Action alternative. 

All livestock grazing would be eliminated by the year 2005 . The 
entire refuge boundary would be fenced where possible. 

Recreational development and use would be about the same as the 
Proposed Action alternative. 


xiv 


I. PURPOSE AND NEED FOR ACTION 





















' 












































































































































Purpose and Need 


I. PURPOSE AND NEED FOR ACTION 


Many wildlife-livestock problems at the Charles M. Russell National 
Wildlife Refuge (CMR) have resulted from conflicting management and 
legislation during 40 years of joint administration by the Fish and 
Wildlife Service (FWS) , Bureau of Land Management (BLM) , and Corps of 
Engineers (COE) . These agencies embrace differing management responsi- 
bilities, goals, and philosophies, and because of numerous federal laws 
applicable to CMR, ultimate management authority was unclear. In addi- 
tion, numerous private and state inholdings complicate management. 

When the Fort Peck Game Range (now CMR) was established in 1936, 

BLM was assigned livestock management, and all forage above the needs of 
wildlife was to be available for livestock grazing. FWS was assigned 
wildlife management responsibility simultaneously with BLM's responsi- 
bility for livestock grazing. Resulting multiple use management did not 
realize the wildlife intent for CMR. In 1976, Congress transferred 
grazing responsibilities to FWS to better realize wildlife potentials. 

The change shifted grazing management from the Taylor Grazing Act to the 
Refuge Administration Act. 

FWS changes in grazing practices have resulted in distrust and un- 
certainty of CMR goals by the livestock industry and federal and state 
agencies. Misunderstanding arises from refuge management, with its 
dominant purpose for wildlife as opposed to adjacent BLM lands, where 
multiple use allows more livestock grazing. 

Recent challenges at CMR are management of archeological and his- 
torical sites, reintroduction of endangered or threatened species, a 
growing regional and national sentiment by environmental groups for 
reduction or elimination of livestock grazing versus a local sentiment 
for more grazing, conflicts regarding consumptive versus nonconsumptive 
use of wildlife, fencing of the boundary, management of CMR as an iso- 
lated wildlife oasis versus management as part of a total ecosystem, 
local recreation demands that may not be compatible with CMR goals, and 
integration of wildlife, recreation, and other natural values. 

FWS believes that the key to meeting its management objectives on 
CMR is to evaluate the current status of the resource and devise a 
master plan, taking into consideration all interests. The planning 
process has included resource inventories, opportunities for resource 
development, conflict analyses, and a scoping process whereby the public 
had opportunities to identify significant issues. 

The scoping process involved people with diverse backgrounds and 
interests in many natural resource areas from across the nation. Some 
toured CMR, providing management recommendations. Public meetings were 
advertised by news media and phone calls. Letters were sent to indi- 
viduals, special interest groups, and Federal, State, and local govern- 
ment representatives. Meetings were held by FWS in Lewistown, Helena, 
Billings, and Glasgow in April 1978, and in Lewistown, Helena, Billings, 
Glasgow, Missoula, Jordan, Great Falls, and Glendive in September 1979. 
COE also held meetings at Glasgow, Lewistown, Glendive, and Jordan in 
June 1979. These efforts resulted in identification of specific resource 
problems and possible solutions, which are developed in the alternatives 
presented in this document. 


1 


This Environmental Impact Statement (EIS) was prepared in compli- 
ance with the National Environmental Policy Act of 1969, and in specific 
response to litigation filed in U.S. District Court, for the District of 
Columbia, entited, National Resources Defense Council, Inc, et al . 
versus Rogers C. B. Morton et al , (June 1975), which required the 
Department of Interior to write EIS's for grazing management on 212 
units of federal rangelands in the West, including CMR. The primary 
responsibility for writing these statements was given to BLM. However, 
on 17 February 1976, amendments to the National Wildlife Refuge System 
Administration Act (Public Law 94-223) were passed, giving BLM’s juris- 
diction of the refuge to FWS, along with the responsibility for writing 
this statement. As a result of negotiation with NRDC, it was agreed 
that the EIS for CMR would cover the entire management of the refuge, of 
which grazing is a major part. 


2 


II. ALTERNATIVES 




Alternatives 


II. ALTERNATIVES 


This chapter defines and evaluates five management alternatives for 
CMR and concludes with a comparison. Management alternatives for wilder- 
ness and minerals have been deferred until a later date; plans for 
managing 15 proposed wilderness areas comprising approximately 161,000 
acres on CMR will be developed after Congressional action on these areas 
is taken. These plans will take into account such items as access, fire 
control, mining, visitor carrying capacity, and wildlife habitat require- 
ments. None of the alternatives compromises wilderness values of exist- 
ing or proposed areas. Also, a specific management plan for prairie 
dogs will be prepared at the end of a current study, since adequate 
information is not now available. 

Management actions for all alternatives must take into account 
special Legislative and Executive mandates for cultural resources and 
endangered or threatened species. Before any action is taken which may 
impact cultural resources, individual site surveys will be completed for 
each area; these requirements will be met under all alternatives as required 
by law. 

Under Section 7 of the Endangered Species Act, a biological opinion 
is required on effects of each alternative on endangered or threatened 
species present or thought to be present on the refuge. The biological 
opinions have been made (Appendix la). In addition, an assessment of 
impacts will be made on the proposed area from which black-footed ferrets 
would be captured for transplanting to the refuge. Black-footed ferrets 
are not expected to be available in the near future. 

Recreation proposals in all alternatives are a combination of 
proposals by FWS, COE, and Montana Department of Fish, Wildlife, and 
Parks (MDFW&P) . A detailed description of each is available for in- 
spection at the FWS office in Lewistown, Montana. All developments 
would be constructed with facilities for handicapped users as required 
by the Architectural Barriers Act of 1968, P.L. 90-480. 

For analysis of wildlife habitat on CMR, 17 indicator wildlife 
species in five major vegetative types (Fish and Wildlife Service 1979) 
were studied. Included were seven game species, seven nongame species, 
and three furbearers (Appendix 2). 

Although habitat requirements are different for various species on 
CMR, habitat deficiencies for many can be corrected by fulfilling require- 
ments of shart-tailed grouse, mule deer, and pronghorns. For example, 
sampling data revealed that improving the habitat for sharp-tailed 
grouse alone will correct habitat for approximately 80 percent of all 
wildlife species using the same habitat. Thus, sharp-tailed grouse, 
mule deer, and pronghorns are referred to consistently throughout the 
document . 

The majority of private and State inholdings are unfenced and in 
common with other land in the allotments administered by FWS, COE, or 
BLM. Livestock stocking rates on these inholdings are determined by the 
landowner or operator as long as they are consistent with recognized 
livestock carrying capacities determined by a valid range survey and the 
season of use is the same as the rest of the allotment. If the owner or 
operator wishes to deviate from the grazing pattern of the allotment, 
the land must be fenced or other measures taken to ensure the operations 
do not affect the majority landowner. 


3 


A mission statement and long range goals for CMR were approved by 
the FWS Regional Director in September 1978. Refuge mission and goals 
were developed in accordance with existing laws, executive orders, and 
policies that guide the National Wildlife Refuge System. 

CMR Mission : 

The mission of CMR is to preserve, restore, and manage in a gener- 
ally natural setting a portion of the nationally significant Missouri 
River breaks and associated ecosystems for optimum wildlife resources 
and provide compatible human benefits associated with its wildlife and 
wi ldlands . 

CMR Goals in Priority Order : 

1) Attain and perpetuate a balanced, natural diversity of plant and 
animal communities favoring endangered or threatened species, then 
all other native species, and finally desirable exotics. 

2) Provide the habitat and necessary resources for recovery or reintro- 
duction of species endangered or threatened with extinction, as 
recommended by approved recovery plans. 

3) Protect and maintain Congressional ly established wilderness areas 
and state and nationally designated historic, cultural, and natural 
areas and objects unique to the Missouri River breaks. 

4) Restore and maintain habitat and other conditions necessary to sus- 
tain optimum populations of mammals and nonmigratory birds. 

5) Manage migratory bird habitats first for production and then for 
use during migration. 

6) Preserve and protect the integrity of the nationally significant 
Missouri River breaks ecosystem. 

7) Protect and maintain the natural resources of the Missouri River 
upstream from the Fred Robinson Bridge to complement and enhance 
the nationally designated Upper Missouri National Wild and Scenic 
River . 

8) Provide grazing for domestic livestock when compatible with wildlife 
and habitat goals. 

9) Provide public understanding and appreciation of the fish and wild- 
life, recreational, cultural, and scenic resources on CMR through 
high quality programs in environmental education, interpretation, 
wildlife observation, hunting, fishing, and other forms of wildlife- 
oriented recreation when compatible with wildlife goals. 

10) Demonstrate and contrast management of wildlife through natural 
ecological processes, areas managed for maximum wildlife abundance 
and diversity, and areas managed especially for compatible public 
uses of wildlife and wildlands. 

11) Coordinate and integrate, where feasible, management of CMR with 
objectives of federal and state agencies and private landowners 
within and around CMR. 

All alternatives must also address the wildlife, range, and recrea- 
tion objectives approved for CMR that evolved from its mission and 
goals. These are: 


4 


Alternatives 


Wildlife Objectives in Priority Order : 

1) Reintroduce peregrine falcons and maintain two eyries by 1990, and 
a third by the year 200 5. 

2) Maintain habitat for and reintroduce a minimum of six pairs of 
black-footed ferrets on six or more prairie dog towns when 
animals are available. 

3) Maintain existing migration habitat for bald eagles and determine 
feasibility of establishing a breeding population. 

4) Improve and maintain sharp-tailed grouse habitat and habitat for 
associated species in good to excellent condition in the ponderosa 
pine-juniper, juniper, and grass-deciduous s^rub types on suitable 
areas to support 30 spring breeding birds/mi (males and females) 
by the year 2005 when weather, predation, life cycles, or other 
natural factors permit. 

5) Improve and maintain pronghorn winter habitat in good to excellent 
condition on suitable sites in the juniper and sage-grassland types 
to support 1,500 wintering animals by the year 2005. 

6) Improve and maintain riparian habitat on the Missouri and Musselshell 
Rivers and other suitable riparian areas in good to excellent 
condition by the year 2005 to benefit wildlife species such as 
white-tailed deer, raccoons, beaver, waterfowl, kingbirds, mourning 
doves, elk, American kestrels, ring-necked pheasants, and turkeys. 

7) Improve and maintain mule deer habitat on the refuge in the sage- 
grassland, ponderosa pine-juniper , and grassland-deciduous shrub 
vegetative types in good to excellent condition to support over- 
wintering populations of 10 deer/mi by the year 2005, in a 
manner that will also benefit sharp-tailed grouse. 

8) Maintain viable prairie dog towns covering between 5,000-10,000 
acres on suitable areas with sizes and patterns desirable for 
black-footed ferrets. Learn the habitat requirements for species 
of special interest and concern that live on or in proximity to 
these prairie dog towns. 

9) Maintain elk habitat in good to excellent condition and improve 
security cover to a level^capable of maintaining a population of 
2.5 over-wintering elk/mi"" in the coniferous and closely associated 
grassland communities by the year 2005. Minimize crop depredation 
on private lands, 

10) Improve waterfowl habitat to good or excellent condition on all 
suitable ponds. 

11) Reintroduce Rocky Mountain bighorn sheep and swift fox into suit- 
able habitat. 

Range Objectives : 

1) Improve range condition and enhance productivity and stability of 
soil resources to complement wildlife objectives. 

2) Provide forage beyond the needs of wildlife to domestic livestock 
where environmental limitations do not preclude such use. 

3) Provide stability and support to livestock users and their operations 
consistent with wildlife objectives. 


5 


Recreation Objectives; 


1) Identify, preserve, and protect all cultural resource values in 
accordance with public law. 

2) Continue to provide opportunities for the public to enjoy sport 
hunting, fishing, and other wildlife/wildlands-oriented recreation, 
including interpretation and environmental education compatible 
with wildlife objectives and the overall refuge mission. 

3) Continue other agency management of developed recreation areas for 
nonwildlife-oriented recreation, compatible with wildlife objectives. 


6 


Alternatives 
No Action 


ALTERNATIVE A 
(No Action) 


ENDANGERED OR UNIQUE SPECIES 


Endangered or unique species management would comply with existing 
federal laws and regulations. Ongoing management actions consist of 
bald eagle surveys, black-footed ferret sign searches, preparation for 
possible peregrine falcon reintroduction, and law enforcement. 

HABITAT MANAGEMENT 


Wildlife surveys on CMR would consist primarily of aerial and 
ground surveys to determine pronghorn, deer, and elk distribution, deer 
and elk population levels, sage and sharp-tailed grouse display ground 
locations, and population levels, waterfowl production, colonial nesting 
bird production, beaver population trends, coyote densities, and prairie 
falcon and golden eagle use. 

Nest structures for geese and five goose and duck brood ponds would 
be maintained near the old Slippery Ann headquarters. A second set of 
goose ponds would be maintained at Fort Peck. A few scattered water 
developments would be constructed and maintained for wildlife and live- 
stock, and suitable ponds stocked with fish. 

The existing small cooperative farming program on the Missouri 
River bottomlands in the west unit would be continued. Farming would be 
conducted on a sharecrop basis with one-third left for wildlife needs. 
Habitat conditions would be monitored by vegetative sampling. 

All wildfires would be suppressed as soon as possible following 
discovery. Those that could be reached by vehicle would be fought with 
hand crews. Aerial retardant would be used if ground crews were ineffec- 
tive. An exception to this policy would pertain to northern Petroleum 
County where fires would be allowed to burn so long as they remained 
confined to the drainage in which they originated. No prescribed burn- 
ing would be used in this alternative. 

Fisheries management would consist of cooperating with the MDFW&P 
in stocking fish and enforcing regulations. 

FWS would control predators to reduce livestock depredations on a 
case-by-case basis upon request of the livestock operator and confirma- 
tion of damage. No prairie dog or other small mammal control would 
occur on the refuge except for human health and safety purposes. Prairie 
dog control would be considered where refuge lands adjoin other landowners 
as a last resort when they are causing problems to the landowner. No 
coyote control would occur to protect other wildlife. 

FORAGE ALLOCATION 


Livestock grazing would remain at current levels. Total federal 
livestock Animal Unit Months (AUMs) would be maintained at 60,108 with 


7 


3,524 in a nonuse status. Vegetation for wildlife used for food, resi- 
dual cover, or other habitat needs would total about 50,000 AUMs. There 
would be a light increase in total forage available for wildlife and 
livestock on a refuge-wide basis totaling approximately 110,000 AUMs by 
1985. 

RANGE DEVELOPMENTS 


Range improvements would continue at present levels with limited 
maintenance or new construction scheduled. 

RECREATION AND CULTURAL RESOURCES 

There would be minor improvements in existing recreation facili- 
ties. The 21-mile reach of the Missouri River downstream from the Upper 
Missouri National Wild and Scenic River, between Fred Robinson Bridge 
and headwaters of Fort Peck Reservoir, would continue to receive limited 
recreation use. 

Some improvement of the visitor contact station at Fort Peck would 
occur, and wildlife pastures at Fort Peck would continue to be maintained 
by COE. 

Periodic maintenance of the existing self-guided wildlife tour 
route near Slippery Ann would occur. Existing access roads and recrea- 
tion areas would be retained with limited maintenance or minor improve- 
ments. Private cabins would be retained. 

Elk and pronghorn hunting would be on a limited (permit) basis 
while hunting for deer, upland game, and waterfowl would be open to all 
license holders. The use of free elk archery permits would be continued 
to collect data on archery hunting. No aerial hunting for coyotes would 
be allowed. All fishing and hunting would be in accordance with state 
regulations, formulated cooperatively by MDFW&P and CMR personnel. 

MITIGATING MEASURES 


Small scale fencing could occur on intermittent and continuous 
streams, ponds, and draws to improve riparian habitat and shrubs. The 
only other mitigating measures would be to select all or portions of the 
Proposed Action, Intensive Wildlife Management, or No Grazing alterna- 
tives . 


8 


Alternatives 
Proposed Action 


ALTERNATIVE B 
(Proposed Action) 


OVERVIEW 


The planning process was guided by the dual agency administration 
of FWS and COE (Appendix 13) , the Executive Order establishing CMR 
(Appendix 4), national policy, information provided by the public, and 
long-range CMR goals. The planning process used for CMR is outlined in 
Appendix lb. The Proposed Action is considered to be a practical solu- 
tion that provides almost all of the wildlife habitat benefits of any of 
the alternatives. These benefits would take longer to occur, but could 
lessen off-refuge impacts. Considering the dual jurisdiction and land 
ownership patterns, it appears to be the most reasonable alternative. 

The following constraints were established by FWS to govern the 
Proposed Action. To the extent these constraints are imposed by policy 
and not legislation, they are subject to change through public evalua- 
tion of the EIS. 

1) FWS funds will not be spent for livestock where wildlife benefits 
cannot be identified in the process. 

2) Water developments, fencing, farming, etc., are generally incon- 
sistent with wildlife goals and will only be used when wildlife 
objectives cannot be accomplished through other measures. 

3) Restoration practices such as shrub planting are consistent with 
wildlife objectives. 

4) Insofar as possible, FWS will coordinate and standardize CMR live- 
stock grazing systems, stocking rates, and seasons of use with 
adjacent landowners in common allotments as long as this does not 
prevent FWS from carrying out its mandates. 

5) Public hunting, fishing, and trapping are appropriate uses of CMR 
lands as long as they are consistent with CMR*s objectives. 

GENERAL 


Passage of Public Law 94-223 in 1976 solved the past jurisdictional 
problems with the BLM. Also, a Memorandum of Agreement was signed by the 
COE and the FWS in 1979. The Agreement was signed to ensure that both 
agencies coordinate all future planning activities on the Charles M. 

Russell National Wildlife Refuge. Joint management by agencies with 
differing legislative mandates creates potential for conflict; therefore, 
efforts would continue to simplify overlapping jurisdiction and eliminate 
potential problems. 

The Proposed Action alternative would reach and maintain the refuge 
objectives. A 33 percent average reduction in grazing would occur by 1990. 
Generally, the refuge would be prescription grazed on a seasonal basis 
at light livestock stocking levels and the response of wildlife habitat 
closely monitored. If wildlife objectives were not being accomplished, 
additional changes in grazing would be implemented on specific areas not 
responding. These actions would include further reductions or increases 
in AUM's allocated to livestock, changes in seasons of grazing use, and 
other changes. 


It is estimated that it will take 5-15 years depending on the 
weather conditions and site characteristics before adequate information 
is available to make these changes or estimate impacts. 

ENDANGERED OR UNIQUE SPECIES 


Two peregrine falcon reintroductions would be made at suitable 
sites, and six pairs of black-footed ferrets and several pairs of swift 
fox would be reintroduced on selected prairie dog towns as animals 
become available. No known source of black-footed ferrets exists at 
present. Twenty to thirty bighorn sheep would be introduced at selected 
sites. Introductions would continue as necessary to establish viable 
populations . 

HABITAT MANAGEMENT 


An essential undertaking would be preparation of a habitat manage- 
ment plan for each allotment by 1990. These plans would spell out 
specific wildlife habitat problems and provide specific management 
actions to correct the problems, such as grazing seasons of use, pre- 
scribed burning, planting, and rest from grazing if necessary. Evalua- 
tion of wildlife habitat on a periodic basis to determine whether wild- 
life objectives were being met in a suitable time frame would occur. 

This would be coordinated with BLM in joint pastures. It is recognized 
that BLM and FWS have different management objectives for livestock 
grazing. Fences would be constructed where necessary to achieve each 
agency’s objectives. The location of these fences would be determined 
after consultation between concerned parties when habitat management 
plans are written for each allotment. Approximately 50 miles of boun- 
dary fence have presently been identified and are discussed further in 
range developments. Additional fencing may be required. These fences 
would not necessarily be on the refuge boundary. They could be con- 
structed in the best and most practical locations. Other possibilities 
would be to locate new water facilities or implement specific grazing 
systems designed to reach each agency's objectives in suitable common 
al lo tments . 

The Habitat Evaluation criteria (Appendix 2) would be upgraded as 
more information becomes available. In addition, various sampling tech- 
niques would be established to monitor at prescribed intervals long-term 
changes in habitat and range conditions. Different treatments or grazing 
capacities would be employed if these evaluations indicated that wildlife 
objectives were not being reached. Other management surveys would be as 
described under the No Action alternative. 

The most significant management actions to achieve habitat objec- 
tives would be reductions of livestock grazing, changing livestock sea- 
sons of use, and habitat treatment practices such as prescribed burning. 
Overall proposed livestock levels would be approximately 33 percent 
below current federal AUM levels on the refuge. Livestock grazing would 
be utilized on a prescription basis, as required, to maintain existing 
plant communities at desired habitat conditions. 


10 


Alternatives 
Proposed Action 


Deciduous shrub quantity and quality would be increased by pre- 
scribed burning of 1,900 acres by 1990, and a total of 7,700 acres by 
the year 2005. Planting would be done on 100 acres by 1990, and a total 
of 500 acres by the year 2005. Habitat analysis indicated deciduous 
shrub communities are in short supply on the refuge, and historical 
accounts indicate shrubs were once more abundant than they are today. 

A combination of actions would be taken to improve the present situa- 
tion. Although a better shrub community could be attained, it would not 
be luxuriant, as CMR does not have the potential, with limited exceptions, 
to provide such communities. The aforementioned habitat management 
plans would determine the best means of re-establishing shrubs on each 
allotment. Management actions would probably be adjustments in grazing, 
burning, and planting, in that order. Shrubs would be planted to re- 
establish a seed source for natural revegetation. It is estimated that 
this would involve approximately 25 acres/year depending on success of 
grazing adjustments and burning. 

Following burning or planting, there would be no grazing allowed 
for two to three years or longer, if necessary, to ensure successful 
establishment of the desired yegetation. 

Cooperative farming and haying would be phased out in the bottoms along 
the Missouri River to restore natural river bottoms. Lure cropping would be 
tried on the east end to decrease elk depredation on adjoining private crop- 
lands. Six miles of fence enclosing about 900 acres would be constructed 
from 1980-2000 to protect selected riparian zones from livestock and enhance 
shrub reproduction. 

Since actions to be undertaken would be constrained by the inter- 
spersed ownership of federal, state, and private lands, several priority 
land purchases totalling approximately 2,000 acres would be attempted on 
a willing-seller basis by 1990. Additional purchases would occur as 
money becomes available. Two allotments would be changed from domestic 
sheep to cattle use by 1990. These allotments are located in the poten- 
tially best pronghorn range on the refuge, but where pronghorn habitat 
components are depressed. Domestic sheep would be eliminated from the 
refuge unless needed on a prescription basis to manipulate vegetation. 

A policy for fire management would include the following points: 

1) no prescribed burning on most shale and badlands sites; 2) no pre- 
scribed burning along the refuge boundary when opposed by adjacent 
owners; 3) little or no prescribed burning on slopes in excess of 40 
percent; 4) prescribed burns of 10-40 acres each on the west half of the 
refuge; 5) suppress all fires in coniferous communities on the eastern 
portions of the refuge where conifers are limited in extent; 6) suppress 
wildfires in identified critical elk calving, sage grouse, and mule deer 
winter habitats where fire may destroy desirable habitat components; 7) 
rehabilitate wildfire burns by planting native browse species on suitable 
sites when necessary; 8) attempt to suppress wildfires in close proximity 
to recreation areas where recreation values may be jeopardized; and 9) 
generally attempt to limit wildfires to 10-40 acres in dense timber 
which is an optimum size burn for deer and elk. This size burn may be 
impractical due to topographic and other factors. Burn sizes may actu- 
ally be 80-100 acres or more. 


11 


Fisheries management would consist of cooperating with MDFW&P in 
stocking programs and enforcement of fishing regulations while trying to 
protect water courses and revegetate any streambanks in poor condition. 

Predator control to reduce livestock losses would be the same as 
the No Action alternative. Coyote control to benefit other wildlife 
species would occur as a last resort as stated in the Final EIS for 
Operation of the National Wildlife Refuge System. Several methods of 
control are listed with killing of coyotes last. Small mammals would be 
controlled only if a health hazard was apparent. Prairie dog control 
would also be the same as the No Action alternative pending outcome of 
an ongoing study. 

FORAGE ALLOCATION 


Livestock grazing on CMR would be substantially reduced to improve 
habitat conditions for wildlife. Proposed livestock grazing levels 
would be 40,482 federal AUMs by 1985, which represents a 33 percent 
average reduction from present federally licensed AUMs. This reduction 
would range from 0-100 percent depending on the allotment (Appendix 5). 
Three small livestock allotments would be eliminated, and four allot- 
ments would be incorporated as pastures into other allotments leased by 
the same permittee. 

Each allotment was examined in terms of existing range conditions 
(Appendices 8 and 9), slope and water factors (Appendix 15), and soil 
limitations (Appendix 7). Concurrently, wildlife habitat conditions 
(Appendix 2) were evaluated by allotment and deficiencies noted. In the 
majority of the areas where habitat evaluation demonstrated existing 
livestock/wildlife conflicts, slope/water factors and soil limitations 
provided the necessary grazing change. In the remaining areas where 
habitat deficiencies affected by livestock grazing still remained, 
grazing was adjusted to allow the achievement of applicable wildlife 
objectives. This process determined that light grazing (0-35 percent 
utilization), coupled with various seasons of use, would achieve the 
diversity of habitat conditions mandated by the refuge goals and objec- 
t ive s . 

Most livestock grazing would continue to be on a seasonal (winter, 
spring, summer, fall, or combination thereof) basis, although spring 
turn-in dates would be later and grazing reduced to light stocking 
levels. Prescription grazing would be employed as a management tool to 
provide certain habitat conditions to benefit a particular wildlife 
species . 

In general, there would be no early spring use in allotments. 
Turn-in dates for livestock would be delayed until significant conflicts 
with wildlife would be avoided (late spring). 

Several allotments have been identified as possessing potential for 
combination into deferred rotation systems with BLM, state, and private 
landholders. Early spring use in existing pastures would be rotated 
with other pastures inside or outside CMR to eliminate spring use in the 
same pastures on a recurring annual pattern. Close cooperation, especi- 
ally between BLM and FWS, would be needed on common pastures to ensure 
successful implementation of any deferred grazing systems. 


12 


Alternatives 
Proposed Action 


Changes in one and possibly two existing rest-rotation systems 
would be considered. Two allotments with rest-rotation systems were 
identified which are not providing desired results in terms of habitat 
values. Recommendations made by Hormay (1980) would be considered when 
management plans for the allotments are written. Periodic evaluations 
of how these grazing systems are providing desired habitat quality for 
wildlife will ultimately determine the degree to which rest-rotation 
would be used as a viable grazing system on the refuge. 

Generally, the other allotments with deferred and rest-rotation 
grazing systems would remain intact to provide a rest period during a 
portion of the grazing sequence with grazing commencing at different 
dates in succeeding years in a given pasture. Early spring use would be 
avoided as much as possible on these allotments because of soil erosion 
problems. Present turn-in dates would not be substantially affected 
under deferred or rest-rotation systems of use so long as the same pas- 
tures would not be grazed at the same time each year. 

In years of below average forage, production due to drought, fires, 
insects, or other natural causes, grazing permits may be suspended in 
whole or in part as necessary to minimize damage to range and wildlife 
resources . 

RANGE DEVELOPMENTS 


Most grazing allotments on CMR adjoin unfenced state and BLM land. 
Preparation of habitat management plans would involve intensive coordina- 
tion with other landowners, especially BLM, to determine specific manage- 
ment actions necessary to meet the individual landowner's objectives. 
Boundary fences would be built where necessary. Fences would be 42 
inches high, 3-strand, with 12 inches between wires. The bottom wire 
would be 18 inches above the ground and smooth in areas where pronghorns 
would likely encounter fences. 

So far, approximately 50 miles of fencing needs have been identi- 
fied along the CMR boundary to keep livestock numbers within authorized 
levels. Fencing would occur in a minimum of six allotments by the year 
2000. Other portions of the boundary would be fenced if problems arise 
regarding unauthorized livestock use. A limited amount of interior 
fence would be built. 

New water development projects would be limited for facilities that 
enhance watershed, wildlife, and recreation programs; however, no allot- 
ment will be left without water. A need for three new stock ponds plus 
one pipeline and several troughs has been identified. Periodic mainte- 
nance of existing range developments would occur on an as-needed basis. 

RECREATION AND CULTURAL RESOURCES 


Public access would be provided to various portions of CMR (Figure 
1) , and water access by boat and plane throughout the length of the 
refuge would be stressed. 

Among new programs would be enhancement and preservation of the 
Missouri River below the nationally designated segment from Fred Robinson 
Bridge to headwaters of Fort Peck Reservoir. The FWS , COE, and MDFW&P 


13 


will coordinate to ensure the best possible fishery management within 
the primary COE mandates of flood control, navigation, irrigation, and 
power generation. 

A cooperative management plan would be prepared with BLM, COE, and 
MDFW&P for the Slippery Ann area by 1990. Of special concern would be 
nearby sites that could replace or complement James Kipp State Park 
which is periodically flooded, the existing wildlife tour route, en- 
hancing opportunities to view wildlife, needed provisions for accommodating 
floaters who use the Upper Missouri National Wild and Scenic River, and 
an interagency visitor contact-interpretive center. Visitor contact 
stations would be constructed at Fort Peck, Malta, and Lewistown in 
cooperation with other interested agencies such as COE, BLM, MDFW&P, and 
Montana Department of State Lands (MDSL) . 

A historic tour route would be designated along the Sand Creek 
trail south of the Missouri River. Various historic buildings and sites 
located along this route would be marked and interpreted. 

A scenic tour route following the existing Knox Ridge road would 
focus attention on the Missouri River Valley and its associated wild- 
life . 

Certain lands such as research natural areas, paleontological 
areas, islands, and special wildlife areas would be identified as en- 
vironmental education study areas for use by various institutions and 
organizations. York Island, a site on Fourth Point, and a limber pine 
community near Hell Creek State Park, would be recommended for research 
natural areas on the eastern portion of the refuge because of their 
unique plant communities. A coniferous forest community lying east of 
the mouth of Two Calf Creek on the west portion of the refuge would be 
recommended for a research natural area because of its vegetative fea- 
tures . 

From Fred Robinson Bridge to Crooked Creek Recreation Area, a 50- 
mile self-guided canoe trail (about 25 miles along the undesignated 
free-flowing segment of the Missouri River and another 25 miles from 
headwaters of Fort Peck Reservoir to Crooked Creek) would be established, 
paralleling the route followed by Lewis and Clark. Where possible, 
natural, historic, and other features would be interpreted along the 
route. 

A 140-mile sail-powerboat tour route would be designated on Fort 
Peck Reservoir, connecting existing and proposed major recreation areas. 

In addition to a brochure describing the route and points of interest 
along the way, signs and markers would be placed at campsites and boat 
access areas along the shore. 

At appropriate locations on the refuge, exhibits would be provided 
to explain wildlife, geologic, historic, and related features. 

As recreation demands and needs dictate, approximately 30 miles of 
backcountry (nonmotorized) and nature trails would be designated at 
several locations. These trails would be self-guiding or could be used 
as part of a guided interpretive program. 

As with the No Action alternative, wildlife pastures would continue 
to be maintained by COE at Fort Peck. Interpretation of the wildlife 
display pastures would be integrated with the visitor contact station at 
Fort Peck. 


14 


UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 

CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


LEGEND 


Q FWS Headquarters 

$ 


Corps of Engineers Headquarters 
Private Cabins 
Research Natural Area 

Upper Missouri National Wild and Scenic River 


> > > Ffee blowing River Preservation 

• Sail / Power Boat Tour Route 

' " Refuge Transportation System 

♦ Sport Fishing Access 

Knox Ridge Scenic Tour Route 

♦ Nature Trail 



-irt 


FIG. 1 RECREATION PROPOSALS 











4 . 4 ;. 



Alternatives 
Proposed Action 


Existing private cabin areas would remain, and no new cottage areas 
would be developed. 

All existing roads and trails including those that have been closed 
would be periodically evaluated to determine those that should be improved 
realigned, or closed. Established roads would be marked to guide visitors 
Cooperative agreements would be negotiated with affected agencies to 
ensure that connecting roads outside CMR were maintained. 

Where compatible with wildlife and in consultation with COE, areas 
for float plane landings on Fort Peck Reservoir would be established as 
needs dictate. 

An additional boat launching, camping, and fishing access site 
would be developed at Fourchette Bay on the north side of the reservoir. 

As demands increase, facilities would be expanded by COE at existing 
recreation areas. Some access roads leading to these sites would be 
improved . 

Wildlife populations would be harvested within the capacity of the 
resource. Primitive sport fishing access sites would be provided at a 
number of locations throughout the refuge. 

Qualified cultural structures and sites would be officially desig- 
nated through nomination to the National Register of Historic Places 
or to other appropriate lists. Surveys of the areas would be conducted 
to comply with Executive Orders or legislation as funding and manpower 
permit . 

MITIGATING MEASURES 


If wildlife objectives were not being accomplished under the Pro- 
posed Action, several courses of action would be available. As ranches 
were sold, grazing privileges could be retired across CMR until approxi- 
mately 15-20 no-grazing areas were established. These no-grazing areas 
would be used by cattle from other actively grazed allotments needing 
rest to produce desired vegetation. Once accomplished, this would 
contribute to the objective of stabilizing livestock use. In drought 
years, some use could be made of these areas when the normally grazed 
areas would not produce enough vegetation for wildlife and livestock. 

If constraints listed at the beginning of this alternative were softened 
to allow construction of stock ponds, fencing, and other management 
facilities, options would be available to mitigate some impacts on 
individual ranchers as well as allow suitable farming and still reach or 
exceed wildlife objectives. Presently, however, stock ponds, fencing, 
and farming are generally inconsistent with refuge goals and are not 
available as mitigating measures. If these options were available, 
ponds at heads of draws would be fenced, eliminating trampling of shrubs 
by livestock. 

Another measure would be to fence riparian zones (intermittent 
streams, river banks, and reservoir shorelines) where desired results 
were not being obtained. These have traditionally been considered as 
sacrifice areas on CMR due to concentrations of livestock that occur 
from normal grazing operations. To restore and maintain all important 
riparian areas without fencing, livestock grazing would have to be 
eliminated in the entire allotment where it occurs (Hormay 1976). 


16 


Minimal farming on the uplands and some bottoms, if done properly, 
could benefit some wildlife on CMR, especially turkeys, ring-necked pheas- 
ants, white-tailed and mule deer, elk, sharp-tailed grouse, raccoons, 
gray partridge, waterfowl, sage grouse, white-tailed jackrabbits, and 
most seed-eating birds. This management practice is also not available 
due to the policy constraints placed on this alternative. 

The areas needing wildlife habitat improvement on the refuge could 
be placed in a no-grazing category for several years, then grazed by 
livestock as stated in the proposal. This would improve habitat condi- 
tions in a shorter time period. 

AUM reductions could be spread over a longer time period than five 
years which would reduce, but not eliminate, impacts to some livestock 
operators using the refuge, but would delay wildlife habitat improve- 
ment . 

Any new facility construction to improve wildlife habitat, range 
resources, or recreation quality would be carefully evaluated to ensure 
that all site limitations are known and considered before construction 
is attempted. 

Should recreation activities result in significant conflicts with 
wildlife, the FWS will coordinate with other agencies to resolve the 
problem. 


17 


Alternatives 

Intensive Wildlife Management 


ALTERNATIVE C 

(Intensive Wildlife Management) 


GENERAL 

This alternative involves several interrelated components: reducing 

grazing to approximately 27,000-30,000 AUMs, purchasing inholdings 
to control grazing, removing private cabins, and intensive wildlife 
habitat manipulations. Under this alternative, AUMs would only be 
allocated to livestock as needed for vegetative manipulation to benefit 
wildlife. Conflicts that arise with the COE concerning the removal of 
private cabins will be coordinated and resolved in compliance with the 
Memorandum of Agreement between the COE and FWS (see Appendix 3, page 
158) . Many private inholdings would be purchased and arrangements made 
with SLB to trade, lease, and possibly sell key state lands. Approxi- 
mately two-thirds (290 miles) of the refuge boundary (400 plus miles) 
would be fenced. Intensive wildlife habitat manipulation proposals such 
as fencing, farming, and pond development would require modification of 
planning policy constraints for CMR (see page 9» paragraph 2). 

ENDANGERED OR UNIQUE SPECIES 


Re introduct ion of peregrine falcons, black-footed ferrets, swift 
fox, and bighorn sheep would occur as in the Proposed Action alternative. 
Bison would be introduced at UL Bend on 30-35 sections of enclosed land. 

HABITAT MANAGEMENT 


Management surveys would be conducted similar to those proposed 
under the No Action alternative with slight expansion in number of 
species sampled and intensity of sampling. Facilities for geese at 
Slippery Ann and Fort Peck would be maintained. Additional waterfowl 
production areas at UL Bend would be created through damming natural 
runoff water into 34 ponds and associated wetlands totaling approxi- 
mately 900 acres. 

Habitat analyses would be conducted as stated under the Proposed 
Action alternative. 

Livestock grazing would be used as a management tool on a prescrip- 
tion basis to remove rank vegetation or to alter vegetation to reach 
desired habitat conditions for wildlife. Extensive burning, planting, 
prescription grazing, and cultivating suitable land would be the main 
management tools under this option. To implement this grazing pattern, 
many private and state inholdings would be acquired. At present, the 
majority of inholdings are unfenced. Fencing some of the isolated 
parcels would be impractical and expensive if private and state lands 
were to be retained under present ownership and grazing practices. 

Shrub quantity and quality would be increased from fair to excellent 
condition by burning 3,800 acres by 1990, and a total of 15,000 acres by 
the year 2005. It is estimated that shrub planting would be carried out 


18 


on 800 acres by 1990, and on a total of 3,000 acres by the year 2005. 

In addition, intensive farming would be conducted on approximately 2,000 
acres of land to provide food interspersed with shelterbelts and other 
cover for deer, upland birds, elk, and other wildlife. This would 
include substantially increasing farming in some river bottoms and other 
suitable areas to increase the food supply for white-tailed deer as well 
as many other riparian species. Some small but important riparian zones 
across CMR would be excluded from big game use by temporary fencing. 

This would allow these zones to revegetate and provide excellent quality 
habitat at which time the fencing would be removed. 

Elk lack adequate security cover from Timber Creek (west) to Fort 
Peck; this would be corrected by planting ponderosa pine at various 
locations. Fire management would be the same as the Proposed Action 
alternative . 

Fisheries management would include stocking and regulations enforce- 
ment as outlined in the Proposed Action alternative as well as protecting 
water courses and revegetating impoverished areas. In addition, some 
bays would be diked off to establish littoral vegetation for spawning, 
and concrete spawning runs would be established for use by salmonids. 

Control of predators to protect livestock and control of prairie 
dogs would be the same as the No Action alternative. Coyote and small 
mammal control to benefit other wildlife species would occur as a last 
resort as stated in the Final EIS for Operation of the National Wildlife 
Refuge System (Fish and Wildlife Service 1976) and the Migratory Bird 
Program Management Document Goal #5 (Fish and Wildlife Service 1980) . 

FORAGE ALLOCATION 


Livestock grazing would be employed as a tool to achieve or main- 
tain desired habitat conditions. Generally, livestock would be grazed 
at moderate levels with alternate spring-summer use. Each year of use 
would be followed by two years of complete rest. Site specific treat- 
ments would vary depending on wildlife species’ needs and the condition 
of the vegetation. Treatments would include specific grazing prescrip- 
tions, and other habitat treatments such as fire. Federal livestock 
levels grazed on an annual basis would be approximately one-third those 
presently authorized. About 23,000 AUMs would be provided for livestock 
use by 1990. Private and state inholdings would be acquired as they 
became available. Wildlife would receive about 87,500 AUMs by 1990 to 
fulfill habitat needs. 

By the year 2005, there would be an estimated maximum of 27,000- 
30,000 livestock AUMs grazed on CMR annually. Wildlife would receive 
about 107,000 AUM’s for food and habitat enhancement. 


RANGE DEVELOPMENTS 


Range improvements would be limited to approximately 290 miles of 
boundary fence to regulate livestock. Interior fencing would be removed 
in smaller pastures, and water facilities would be maintained where 


19 


Alternatives 
Intensive Wildlife Mgmt 


needed. Range improvements such as fences or ponds on marginal sites 
having soils, geological hazards, or wildlife conflicts would be removed 
or allowed to deteriorate. Soil ripping would occur on nearly all 
suitable sites (38,000 acres) on the refuge, with the exception of 
wilderness areas, to improve wildlife habitat and reduce soil erosion. 

RECREATION AND CULTURAL RESOURCES 

This alternative is similar to the Proposed Action alternative for 
recreation. However, there would be a somewhat lower level of public 
use and facility development. 

Unlike the Proposed Action alternative, no backcountry (nonmotorized) 
trails would be developed, and only nature trails would be provided. 

Private cabins presently situated on CMR at The Pines, Fort Peck, 

Rock Creek State Park, and Hell Creek State Park would be removed as the 
leases terminate. The areas would be rehabilitated into suitable wild- 
life habitat. 

There would be no development of low density recreation areas; 
additional fishing access sites would be provided instead. Existing 
high density recreation areas would be expanded by COE as needs dictate. 
Any recreational uses or activities conflicting with normal wildlife 
activities would be controlled by excluding such use during critical 
seasons . 

Any new facility construction to improve wildlife habitat, range 
resources, or recreation quality would be carefully evaluated to ensure 
that all site limitations are known and weighed in terms of whether or 
not the proposed construction would be feasible. 

MITIGATING MEASURES 


Retirement of all livestock grazing in a given area could be employed 
if competition with wildlife is determined to be a limiting factor 
affecting a wildlife species. 

Gradual reductions in the livestock grazing program would soften 
impacts of reduced livestock levels on individual operators, but would 
delay wildlife habitat improvement. 


20 


ALTERNATIVE D 


(Multiple Use) 


GENERAL 

This alternative would not be possible to implement unless Con- 
gressional action changed CMR from a national wildlife refuge to a 
multiple use management area. 

ENDANGERED OR UNIQUE SPECIES 

Re introduct ion of peregrine falcons, swift fox, and bighorn sheep 
would occur as in the Proposed Action alternative. One or more pair of 
black-footed ferrets would be reintroduced, if they became available. 

HABITAT MANAGEMENT 

Management surveys would continue as described in the No Action 
alternative, as would development of areas for geese at Slippery Ann and 
Fort Peck. Waterfowl ponds and nesting structures would be expanded at 
UL Bend through damming of natural runoff waters to include 34 ponds and 
associated wetlands totaling about 900 acres. 

Grazing would be initially reduced, and then gradually increased 
over current levels as range conditions improve and portions of the 
riparian zone along the Missouri River would be grazed on a prescription 
basis. Cooperative farming would continue as described under the No 
Action alternative or be increased. 

Predator control to reduce livestock losses would occur under the 
same guidelines as on adjacent land, including aerial gunning. Prairie 
dog control would be as stated under No Action. Other small mammal con- 
trol would be as stated under Intensive Wildlife Management. Coyote 
control to protect other wildlife would be as stated under the Proposed 
Act ion. 

FORAGE ALLOCATION 


Livestock would receive approximately one-half the allocated for- 
age. Initially, there would be temporary reductions in present live- 
stock AUMs from 56,000 active to 52,000. The Rock Creek ungrazed area 
„ould be opened to livestock grazing. Temporary livestock nonuse of 
allotments in deteriorated condition and soil ripping of all suitable 
panspots and dense clay sites would provide a forage increase of several 
thousand AUMs for livestock and wildlife over present levels because of 
improved range conditions. Wildlife would ultimately be allocated about 
60,000 and livestock 61,000 AUMs on federal lands within the refuge. 


21 


Alternatives 
Multiple Use 


RANGE DEVELOPMENTS 


As many as 12 additional allotments would have new grazing systems 
implemented by the year 2005. The six allotments presently in rest- 
rotation systems and the three deferred rotation systems would be main- 
tained . 

Range improvements such as fencing, water development, or mechanical 
treatment of soils would be based upon allotment needs. 

RECREATION AND CULTURAL RESOURCES 

All recreation proposals discussed in the Proposed Action alterna- 
tive would occur. In addition, a backcountry foot and horse trail 
extending the length of CMR on the north side of the Missouri River 
would be designated. This trail would provide the closest land route 
paralleling the historic Lewis and Clark trail. Some primitive camp- 
sites would be located along this route, and historic and natural fea- 
tures would be interpreted. The trail would be nominated as a component 
of the Lewis and Clark National Historic Trail upon completion of a 
comprehensive plan for the historic trail by the National Park Service. 

A perimeter shoreline scenic road extending 21 miles along the 
north shore of Fort Peck Reservoir on the east side of the refuge would 
be constructed. The road would be built by COE near the lakeshore to 
provide optimum viewing opportunities. Primitive campsites would be 
established at a number of locations throughout the refuge. High and 
low density recreation areas described for the Proposed Action alter- 
native would be expanded as needs dictate. 

MITIGATING MEASURES 


Fencing riparian zones and ponds where no rotation systems are em- 
ployed would encourage development of riparian communities. Otherwise, 
vegetation in these important locations would not attain desired levels. 

Implementation of several new rotation grazing systems on the 
refuge should provide some increased habitat quality and may eliminate 
the need to fence riparian areas in allotments with rotation systems. 

Livestock allotments not meeting management goals could be placed 
in a nonuse status for as long as needed to achieve desired results. 
Operators would be required to accept nonuse or take use in another 
portion of the refuge. 

Habitat manipulation treatments would be provided if needed to 
maintain a diversity of habitat conditions to favor certain wildlife 
species. The proposed levels of livestock grazing would limit wildlife 
habitat potential. An improvement would occur under this alternative, 
but the amount of improvement over present levels would be slight. 

Any new facility construction to improve wildlife habitat, range 
resources, or recreation quality would be carefully evaluated prior to 
work initiation to ensure that all site limitations are known. 


22 


ALTERNATIVE E 


(No Grazing) 


GENERAL 


This alternative would not be in compliance with Executive Order 
7509. The Executive Order requires that excess forage be allocated to 
livestock, and this alternative allocates none. The purchase of all 
private and state lands would require changes in SLB policy and large 
increases in funding. 

ENDANGERED OR UNIQUE SPECIES 

Reintroduction of peregrine falcons, black-footed ferrets, swift 
fox, and bighorn sheep would occur as in the Proposed Action alterna- 
tive. 

HABITAT MANAGEMENT 


Management surveys and habitat analyses would be implemented as 
stated under the Proposed Action alternative. 

Prescribed burning of 11,300 acres would enhance vegetative pro- 
ductivity, particularly for forb and shrub species. In addition, 500 
acres would be planted to shrubs, and six miles of temporary wildlife 
exclosure fence would be constructed around acreage totaling 960 acres; 
2,000 acres would be cooperatively farmed. Ponderosa pine would be 
planted to fulfill elk habitat requirements. All private and state 
lands would be acquired through purchase or exchange. 

Fire suppression would be as outlined in the Proposed Action alter- 
native. Prescribed burning would follow guidelines described in the 
Proposed Action. Fisheries management would be as stated in the Proposed 
Action alternative. 

Prairie dog and small mammal control would be the same as the No 
Action alternative. Coyote control would occur as required for the 
benefit of other wildlife species. There would be no predator control 
on the refuge to protect livestock as no livestock would be present. 
Predator control to reduce livestock losses on adjacent lands would be 
as stated in the No Action alternative. 

FORAGE ALLOCATION 


Livestock grazing would be reduced by about 10 percent annually through 
1990 on federal lands. All federal AUMs would be retired by the year 
2005. Private and state inholdings would be purchased or acquired 
through exchange, and these AUMs would be retired by the year 2005. 

All forage produced beyond plant and soil resource needs would be 
available for wildlife food and cover. Range conditions would improve 


23 


Alternatives 
No Grazing 


substantially, and essentially, all the good condition range would be in 
excellent condition by the year 2005. This would provide wildlife food 
and cover. 

RANGE DEVELOPMENTS 


Range improvements would involve soil ripping as much as 10,000 
acres of panspots and dense clay range sites to improve vegetative pro- 
ductivity for wildlife food and cover. A few larger reservoirs would be 
maintained for waterfowl production and, in some cases, fishing. Nearly 
all other range improvements would be removed or allowed to deteriorate. 
The refuge boundary would be fenced to prevent unauthorized livestock 
use. All fences would be constructed as stated in the Proposed Action 
alternative . 

RECREATION AND CULTURAL RESOURCES 


There would be no additional facility development or changes from 
the Proposed Action alternative. 

Any new facility construction would be evaluated prior to work ini- 
tiation to determine site limitations and whether or not the proposed 
project would meet the desired objective in view of known site limita- 
tions . 

MITIGATING MEASURES 

If habitat quality for wildlife species associated with several 
vegetative communities declined, treatments such as prescribed burning, 
chemical treatments with herbicides, or plowing could be employed to 
promote habitat diversity to benefit these species. 

Gradual reductions in livestock levels would soften the impact upon 
livestock operators, but would delay wildlife habitat improvement. 

There would be no other mitigating measures to help the livestock opera- 
tors . 


24 


COMPARISONS OF ALTERNATIVES 


It must be recognized that a complex and controversial situation 
occurs at CMR due to Fort Peck Dam and Reservoir, state and COE recrea- 
tion areas, the town of Fort Peck, private and state inholdings, and 
past management practices where livestock was equal or dominant to 
wildlife (the 1952-53 range survey allocated 62 percent of the total 
AUMs to livestock and 38 percent to wildlife) . 

The Proposed Action alternative would attain habitat objectives for 
wildlife refuge-wide by 2005. Moreover, elk and pronghorns would re- 
ceive additional benefits as they move on the refuge for part of their 
life cycle. The refuge would be managed in a natural setting for the 
most part, with intensive wildlife habitat and range improvement pro- 
grams held to a minimum. Livestock grazing would be permitted, gener- 
ally, under a seasonal use basis at light stocking levels. Special 
prescription grazing would be used in those areas where light stocking 
rates were not satisfactory. Generally, this level of grazing has been 
determined to be consistent with wildlife objectives. The Proposed 
Action would be accomplished at moderate cost, with significant in- 
creases in wildlife values. 

Although it is the most desirable for wildlife, the Intensive 
Wildlife Management alternative would reduce the naturalness of the 
refuge and be very costly to implement. Purchasing many of the private 
inholdings would be expensive, and a change in SLB policy to allow state 
land to be leased, exchanged, or sold would be required. FWS policy 
would be modified to allow intensive habitat manipulation such as farm- 
ing, fencing, and pond development. Phasing out of private cabins would 
require resolution within the Memorandum of Agreement with COE. 

Livestock would be utilized as a management tool to achieve desired 
habitat conditions and wildlife objectives by the year 2005 or before. 
However, consolidation of many inholdings into federal ownership would 
facilitate CMR management as a total refuge. Also, cooperative farming 
would provide key areas of increased diversity and food sources for 
wildlife . 

As compared to the Proposed Action, changes in livestock numbers 
under Intensive Wildlife Management would not significantly enhance 
wildlife habitat unless all other proposed treatments were also pro- 
vided. However, intensive developments as proposed by the Intensive 
Wildlife Management alternative are inconsistent with current policy 
constraints. On a dollar for dollar basis, the Proposed Action provides 
a greater benefit to wildlife than Intensive Wildlife Management. 
Wildlife objectives refuge-wide would be met or exceeded before the 
year 200 5. 

The Multiple Use and No Action alternatives do not provide a wild- 
life refuge situation. Livestock grazing would be equal to or above 
wildlife for resource allocations. While popular with area or regional 
residents, these alternatives fall short of accomplishing the wildlife 
habitat potential of CMR. Management under Multiple Use could occur 
only if changed by Congressional action. 


25 


Comparisons 


The complete elimination of livestock from the refuge under the 
No Grazing alternative or severe reductions in the Intensive Wildlife 
Management alternative would likely cause wildlife habitat adjacent to 
the refuge to decline as livestock operators attempt to make up for 
forage no longer available from Federal lands by increasing stocking 
levels on private lands. Private land closures to public use, already a 
problem in the area, could be expected to accelerate, further jeopard- 
izing farmer/recreationist /State/Federal relations. Land purchase and 
total fencing of the boundary would be expensive, and the additional 
benefits gained for wildlife would be slight. Wildlife objectives would 
be met or exceeded by the year 2005 for most wildlife species. 

Recreation would continue with no major change or emphasis from 
present management under the No Action alternative. Under the other 
alternatives, there would be more emphasis on providing the public an 
opportunity to enjoy compatible wildlife recreation. Preservation of 
cultural resources in compliance with Executive Order 11593 would occur 
in all alternatives. Roads to recreation areas, additional fishing 
access sites, expansion of some existing recreation areas, development 
of a scenic tour route and interpretive facilities, and a new recreation 
area on Fourchette Bay are proposed for all but the No Action alternative. 

A notable difference under the Intensive Wildlife Management alternative 
would be the elimination of private cabins from the refuge. The Multiple 
Use alternative proposed additional recreation development. Except for 
the No Action alternative, participation in wildlife-oriented recreation 
activities would be expected to increase, as wildlife populations increase, 
due to the greater opportunities for viewing, photographing, and hunting. 

Due to the remoteness of the area, rising costs of fule for transportation, 
the small increase in population that is projected, and competing 
recreation resources in the region, recreation use on CMR is not expected 
to significantly impact wildlife under any of the alternatives. Table 1 
summarizes how the alternatives would impact the major areas of concern 
at CMR. 

SOCIO-ECONOMIC COMPARISONS 


None of the alternatives have a significant effect on income or 
employment in the six-county region. As Table 3 shows, net employment 
effects for all the alternatives involve changes (positive and negative) 
of less than 1 percent in employment. The net change in direct and 
indirect employment with the Proposed Action is a loss of seven workers 
in 1978-90 and two from 1986-2005. 

The direct effect on the ranchers, while of greater significance 
than to the regional economy, is still relatively insignificant. As 
Table 3a illustrates, the Proposed Action results in only a 3 percent 
loss in gross income or sales. The reason for the lack of significance 
is that a majority of the ranchers are dependent on the CMR on an average 
for only 13 percent of their livestock forage. Direct losses in hired 
labor is less than five workers for any alternative. 

The direct effect on the tourism dependent sectors (retail trade, 
services, and gasoline) from the change in recreation is positive for 
all alternatives, except Intensive Wildlife Management. Direct and 


26 


Table 1. Summary comparison of implementing various management alternatives on 
Charles M. Russell National Wildlife Refuge, Montana. 


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27 


quals an improvement in quality and/or quantity from present condition. 
Is a lowering in quality and/or quantity from present condition. 


Table la. Direct plus indirect impacts of change in livestock production on sales and employment. 


Comparisons 


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28 


is applied to changes in livestock industry sales. The assumption that households respend part of 
their incomes in the local economy and that all of livestock output is exported out of the 
six county study region provides an upper bound on local impacts. 


Table 2. Direct plus indirect impacts in tourist visits on sales and employment. 


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Table 3. Total Impacts of Change in Livestock Production and Tourism. 


Management 

Alternatives 


Total Change 
in Sales 

Total Change 
in Employment 

Percent Change in 
Employment 

Proposed Action 

1990 

$- 

763,579 

- 9 

-.1% 

2005 

Intensive Wildlife 


451,320 

- 2 

-.03% 

Management 

1990 

- 

2,098,661 

-31 

-.5% 


2005 

- 

2,797,542 

-48 

-.8% 

Multiple Use 

1990 

+ 

13,187 

+ 5 

+ .09% 


2005 

+ 

1,635,392 

+37 

+ .6% 

No Grazing 

1990 

- 

1,242,372 

-15 

-.2% 


2005 

- 

2,398,400 

-30 

-.5% 


Source: Calculated 

from data shown on 

Tables 1 and 2. 

Table 3a. Comparison of Direct Effect 

on CMR Ranchers. 

Management Alternatives 

Percent Change in Gross Income and Sales 

Proposed Action 

1990 

-3.2% 


2005 

-3.3% 

Intensive Wildlife 
Management 

1990 

-6 . 8% 


2005 

-6.0% 

Multiple Use 

1990 

-2.3% 


2005 

- .7% 

No Grazing 

1990 

-5.3% 


2005 

-10.5% 


Source : 


Linear Programming Outputs. 


See Appendix for detailed Tables. 


indirect employment is slightly increased in the tourism dependent 
sectors. The changes (positive and negative) in regional employment 
from the recreation components of the plan are relatively insignificant. 

Thus, no alternative under consideration has, in the aggregate, any 
significant impact to either local or regional employment or sales. See 
Appendix 13 for a detailed discussion of the methodology involved in 
estimating the indirect or secondary economic effects. 

The detailed methodology used for estimating the economic impacts 
to the ranchers is presented in Appendix 10. 


31 


III. AFFECTED ENVIRONMENT 



Affected Environment 


III. AFFECTED ENVIRONMENT 


OVERVIEW 


The Missouri River has long served as an access route to Montana 
and the west. Although the river still receives limited use for trans- 
portation, it is primarily a recreational waterway. The "breaks," ero- 
sional interruptions in the river’s escarpment, once supported primitive 
man and a diversity of animals. Today man is still on the scene, but 
many wildlife species, including plains grizzlies, bison, Audubon big- 
horn sheep, and wolves have vanished from the breaks. 

CMR embraces 1,094,301 acres of land and water and stretches 125 
miles from the Fort Peck Dam west along the reservoir and Missouri River 
in northeastern Montana (Table 4). Private individuals own about 51,000 
acres, and the State of Montana owns about 35,000 acres within the CMR 
boundary. These inholdings are scattered and vary in size from 40 to 
almost 5,000 acres. 

Table 4. Land and water acreages within the Charles M. Russell 
National Wildlife Refuge, Montana. 


Area 


Acres 


Fort Peck Reservoir 

(at maximum operating pool) 

249,000 

Federal lands 


760,000 

State lands 


35,645 

Private lands 


49,656 

Total land 

and water acres 

1,094,301 


The area now known as CMR was originally withdrawn from the public 
domain by President Franklin D. Roosevelt under Executive Order 7509 in 
1936; initially, it was called the Fort Peck Game Range. As outlined in 
the Executive Order, the primary purpose of the range was: 

". . .for the conservation and development of natural wildlife re- 
sources and for the protection and improvement of public grazing 
lands and natural forage resources .. .natural forage resources 
therein shall be first utilized for the purpose of sustaining in a 
healthy condition a maximum of four hundred thousand (400,000) 
sharptail grouse, and one thousand five hundred (1,500) antelope, 
the primary species and such nonpredatory secondary species in such 
numbers as may be necessary to maintain a balanced wildlife popula- 
tion. . .Provided further, that all the forage resouces within this 
range or preserve shall be available, except as herein otherwise 
provided with respect to wildlife, for domestic livestock..." 


32 


In 1963, the Fort Peck Game Range was redesignated the Charles M. 
Russell National Wildlife Range by Public Land Order 2951, in honor of 
Montana’s great cowboy artist. With renaming of the area, the Secretary 
of Interior reaffirmed the primary purpose and mission of CMR as a unit 
of the National Wildlife Refuge System, with primary responsibilities 
for administration of the area resting with FWS . BLM, however, con- 
tinued to administer the livestock grazing program, subject to the 
program and policy requirements of FWS. On 27 February 1976, the admin- 
istrative status of CMR and all other game ranges in the nation was 
again changed by the signing of Public Law 94-223. This brought to a 
close the joint management between BLM and FWS. Public Land Order 5635 
(1978) changed the name of the game range to Charles M. Russell National 
Wildlife Refuge (Table 5). 


Table 5. Major documents affecting the Charles M. Russell 
National Wildlife Refuge, Montana. 


Document name 

No. 

Date 

Subj ect 

Executive Order 

6491 

12/12/33 

Ft Peck Dam (COE) 

91 

91 

6707 

05/09/34 

If II II II 

II 

91 

6841 

11/09/34 

II II II II 

II 

II 

7331 

04/03/36 

1? 9? If II 

II 

II 

7509 

12/11/36 

Ft Peck Game Range 

If 

II 

9132 

04/13/42 

Ft Peck Dam (COE) 

Secretarial 

Order 

2843 

11/17/59 

Transfer jurisdiction 

Public Land 

Order 

2951 

02/25/63 

Name change (FWS) 

II II 

II 

4588 

03/25/69 

UL Bend National Wild- 
life Refuge (FWS) 

Public Law 


94-223 

02/27/76 

FWS sole administrator 
of the Wildlife Range 

Public Land 

Order 

5635 

04/25/78 

Name change to Refuge 
(FWS) 


Although Public Law 94-223 vested management authority of CMR with 
FWS, BLM still retains management authority over the Upper Missouri 
National Wild and Scenic River, part of which flows through CMR, as 
provided by Public Law 94-486. 


33 


Affected Environment 


Conflicting legislation and mandates exist between FWS and COE. A 
Memorandum of Agreement (Appendix 3) has been signed by both agencies and 
is guiding current management of the area. About 8,190 acres are occupied 
by supporting facilities such as powerhouses, dam, townsite, and maintenance 
areas. Special public use areas have been identified by COE for devel- 
opment of water-based recreation at 16 locations. Three areas are 
presently leased by MDFW&P as State parks. The Bureau of Reclamation 
is responsible for power distribution. 

Among other agency-management authorities on CMR is MDFW&P. The 
department, together with FWS, manages resident game and fish. State 
school lands within CMR, generally located in sections 16 and 36, are 
administered by MDSL. Status of these lands is similar in many respects 
to that of private inholdings. 

Construction and maintenance facilities for US Highway 191 on the 
west side of CMR and State Highway 24 near Fort Peck on the east are 
administered by the Montana State Highway Department. Certain aspects 
of livestock grazing within CMR, such as the control of disease out- 
breaks and branding of cattle, are managed by the Montana Livestock 
Board . 

The special mission of the National Wildlife Refuge System of which 
CMR is a part is to provide, manage, and safeguard a national network of 
lands and waters sufficient in size, diversity, and location to make 
available now and in the future public benefits associated with wildlife 
over which the federal government has responsibility, particularly 
migratory birds and endangered species (Fish and Wildlife Service 1979). 

The broad objectives of the National Wildlife Refuge System are to: 

1) Preserve, restore, and enhance in their natural ecosystems all 
species of animals and plants that are endangered or threatened 
with becoming endangered on lands of the National Wildlife Refuge 
System. 

2) Perpetuate the migratory bird resource for the benefit of people. 

3) Preserve the natural diversity and abundance of mammals and non- 
migratory birds on refuge lands. 

4) Provide understanding and appreciation of fish and wildlife ecology 
and man's role in his environment and to provide visitors at ser- 
vice installations with high quality, safe, wholesome, and enjoy- 
able recreational experiences oriented toward wildlife. 

CLIMATE 


The climate of the CMR region is typical of the high plains in 
North America with moderately cold winters (average January minimums 
near 0°F) having occasional cold periods exceeding -20°F. Summers are 
generally pleasant (averaging in the 80° 's during afternoon hours) with 
occasional hot periods exceeding 100°F. Low humidity, high temperatures, 
and moderate to strong winds cause rapid loss of soil moisture. Mean 
annual precipitation is 12-13 inches with about 70 percent occurring 


34 


from Apr il-September . Due to the dominantly heavy-textured soils, 
runoff is rapid, often exceeding 50 percent of the total precipitation. 

The average frost-free period is about 120 days. CMR is also subject to 
intense lightning storms from late July-early September, often resulting 
in wildf ires . 

GEOLOGY 

The Missouri and Musselshell rivers flow through deep valleys with 
narrow flood plains lying 500-1,000 feet below the average elevation of 
surrounding uplands. Elevations vary from slightly over 2,000 feet 
above mean sea level (msl) near Fort Peck Dam to over 3,200 feet in the 
Seven Blackfoot area. Three main landforms, uplands, breaks, and flood 
plains, dominate CMR and the surrounding area. Uplands are level-to- 
rolling prairies dissected by intermittent streams flowing toward the 
Missouri River in a generally eastward direction. These are the sagebrush- 
grassland plains typical of eastern Montana. 

The breaks lying adjacent to the Missouri River are typified by 
dissected, rough terrain often culminating in spectacular badlands. This 
topography is common to a strip of land 2-10 miles wide along the Missouri 
River and varies from low, barren hills of the Big Dry area south of 
Fort Peck to severely eroded coulees of the Seven Blackfoot and Burnt 
Lodge areas and the juniper, pine, and grassland ridges on the western 
half of CMR. Approximately 40-50 percent of lands within CMR consist of 
steep ridges and eroded coulees. 

Flood plains occur along the Missouri and Musselshell rivers at 
upper extremities of Fort Peck Reservoir and along some of the larger 
drainages. These developed from pre-glacial river and stream alluvium 
and are characterized by heavy clay soils, deciduous trees, sagebrush, 
and grassland. These flood plains are comparatively flat and vary in 
width from 25 yards-2 miles. 

The Judith River formation outcrops west of Rock Creek in Phillips 
County in major stream valleys. It is composed of several hundred feet 
of interbedded shale, siltstone, and sandstone with scattered beds of 
lignite and bentonite. This formation has good stability, but its out- 
crop area is limited to steep slopes. 

Bearpaw shale underlies more of CMR than any other formation. The 
breaks west of UL Bend are almost entirely composed of this shale as are 
lower slopes east of UL Bend, except in the central and southern parts 
of Big Dry Arm. Bearpaw shale is almost entirely composed of dark gray, 
clayey shale and includes thin beds of bentonite. The predominant parti- 
cle size of this formation is clay, and the predominant clay mineral 
found in Bearpaw shale is montmoril Ionite . As a result, this unit 
swells when exposed in steep slopes and erodes rapidly at many loca- 
tions . 

Fox Hills sandstone is composed of yellowish gray sandy shale, 
claystone, siltstone, and/or very fine-grain sandstone and grades upward 
into relatively thick beds of resistant fine and medium-grain yellowish 
brown sandstone. The formation is generally found in areas of high 


35 


Affected Environment 


relief along Fort Peck Reservoir such as Larb Hills, Harper Ridge, 
and much of Garfield County. Along Big Dry Arm, Fox Hills sandstone is 
found south to Rock Creek (east) . 

The Hell Creek formation is generally found above 2,500 feet in 
elevation in the central and eastern parts of CMR. The formation is 
composed of unconsolidated fine sediments such as claystone, shale, 
siltstone, and sandstone. Some of the clay and silt-rich zones of the 
formation tend to shrink and swell during excavation or when exposed to 
„ater . 

Fort Union formation is found in Garfield and McCone counties, east 
and west of Big Dry Arm and south of Rock Creek (east). The formation is 
also found in the highest parts of Larb Hills. Tullock member, most 
widely found subunit of the Fort Union formation on CMR, is light gray 
to dark gray shale alternating with sandy shale and gray to buff sand- 
stones. Lignite beds are also found in association with this member. 

This formation responds similarly to the Hell Creek formation to most 
development activities. 

Glacial till is found at scattered locations, particularly between 
Rock Creek (west), Phillips County, and Valentine Creek. This is dense, 
clayey material with characteristics similar to Bearpaw shale. Outwash 
and related deposits are found west of UL Bend on low benches and in the 
Missouri valley, in the lee of bedrock ridges. These latter deposits 
are porous and stable. 

The historical rock record exposed on CMR dates to almost 80 
million years bp (before present) or Late Cretaceous. Sedimentation 
dominated the area until about 58 million years bp. For the next 55 
million years, sediments were successively eroded away as the plains and 
surrounding areas were sporadically uplifted. In the past 3 million 
years, glaciers advanced over the area, the most recent retreating north- 
ward about 20,000 years bp. Construction of Fort Peck Dam in 1937 
further altered CMR's landscape. 

Ice jams cause the highest levels of flooding on major streams such 
as the Missouri River, Big Dry Creek, and Musselshell River. Snowmelt 
runoff causes the greatest flood flow volumes on these same streams. 

High flows can occur on these streams any time from January-August. 
Rainstorms cause major flooding on smaller drainages. 

All stream channels flowing through unconsolidated material meander 
over time. The Missouri River upstream of Fort Peck Reservoir has 
shifted as much as 2,000 feet in about 65 years at average rates up to 
30 feet/year. The Fort Peck Reservoir delta is the area of greatest 
channel change and sedimentation; other areas of channel change and bank 
erosion are found on most upstream portions of most stream bottoms. 

Areas of current and past landslide activity cover about one-third 
of the surface area of CMR. Steeply sloping areas in the western 
Bearpaw breaks, Garfield County, Larb Hills, and Harper Ridge have the 
most significant number of landslides. Landslides are of several types; 
slump-earthf lows are the most common. Rapidly moving debris flows also 
occur, especially in the western Bearpaw breaks. 

Piping is an important erosional process in the Hell Creek forma- 
tion and in landslide deposits. Pipes may collapse or create general 
ground instability. Areas of classic piping on CMR occur at Hell Creek, 
Big Dry Arm, and other locations. 


36 


Results of a mineral survey of CMR (Geological Survey 1979) indi- 
cate that parts of the area have a moderate potential for oil and gas, 
low to moderate potential for lightweight aggregate, bentonite and coal, 
and low to nil potential for other mineral commodities such as uranium 
or gold. Oil accumulations probably lie at depths greater than 4,000 
feet. The most likely area of accumulation underlies the western part 
of CMR. 

There is a good possibility that the entire refuge is underlain by 
shallow natural gas deposits. Significant resources of this type are 
already being developed in the Bowdoin field and on flanks of the 
Bearpaw Mountains. The gas deposits, if present, would occur at depths 
of less than 2,000 feet. 

Bentonite resources are estimated at about 4.3 billion tons. 

Highest quality bentonite beds are found in Bearpaw shale, particularly 
west of Nichols Coulee in the Siparyann bed. This bed ranges in thick- 
ness from 1-6 feet at the outcrop. Bentonite resources east of Nichols 
Coulee are considered of low potential because of thinness and poor 
quality. Bentonite on CMR is of unacceptable quality as drilling mud, 
but acceptable for the casting industry to bind molding sand and pos- 
sibly by the taconite industry to bind finely ground iron ore into 
pel lets . 

Bearpaw shale has a moderate potential for use as lightweight 
aggregate. Shale sequences high in bentonite content are the most 
suitable. The refuge contains significant quantities of sand and 
gravel; one gravel pit is currently in use near Hell Creek. 

CMR is estimated to contain over 290 million short tons of coal. 

Of this total, the Judith River formation may contain about 190 million 
short tons in beds averaging less than 2.5 feet in thickness and which 
contain about 40 percent ash. About 100 million short tons of coal are 
found in Hell Creek and Fort Union formations in beds ranging from 1-5 
feet in thickness. 

SOILS-WATER RESOURCES 


Four major soils orders are represented on the refuge. They are 
Entisols (soils characterized by very limited development), Aridisols 
(well-developed soils formed in a dry environment), Mollisols (soils 
with surface layers (horizons) noticeably darkened by organic matter 
accumulations), and Vertisols (soils that have a self-plowing action 
because of high shrink-swell rates associated with varying moisture 
levels) . 

Mollisols are prairie soils generally found in areas of higher 
rainfall than found on the refuge; their extent is very limited here. 

Aridisols present on CMR are composed of two types or suborders: 
those characterized by salt and clay accumulations below the surface, 
resulting in a relatively impervious subsoil, and those with no sig- 
nificant salt or clay accumulations. These latter types represent the 
most significant agricultural potential of any soils present because of 
their fertility and areal extent. They are found on the more gentle 
slopes of CMR. Garfield and McCone counties most typically contain 
these soils, which are generally derived from sandstone or alluvium in 
sedimentary uplands. 


37 


Affected Environment 


Entisols are typically found on the breaks portion of CMR. The 
vegetated surface is quite unstable on these steeply sloping breaks, and 
soils are poorly developed. Other Entisols include those present on 
flood plains of rivers and major creeks in the area. Parent materials 
(unconsolidated minerals or organic matter from which soils are derived) 
for these Entisols include alluvial deposits laid down by streams or 
sedimentary deposits (siltstone, sandstone, or clay from Bearpaw shale). 

Vertisols are most commonly associated with the very fine-textured 
Bearpaw shales and are generally located north of the Missouri River. 

They are typically found on strongly sloping sedimentary (Bearpaw shale) 
uplands or as fans or terraces formed below the Bearpaw shale. 

In addition to topographic features which affect soils, as described 
previously, geologic formations such as Bearpaw shales or glacially 
derived deposits have a definite effect on soils and soil-forming 
processes. Bearpaw shales and glacial till deposits occur mainly north 
of the Missouri River on the east side of the Musselshell River and on 
both sides of the Missouri to the west of the Musselshell River. Soils 
in Garfield and McCone counties are more commonly derived from sandstone 
deposits or are formed as alluvial deposits from sedimentary uplands. 

Concerning limitations of those soils present, Aridisols and 
Mollisols are generally amenable to cultivation and respond well to good 
management practices. Vertisols and Entisols are generally unsuited to 
agriculture because of their salt content, low productivity, and topo- 
graphic features which are generally accompanied by high erosion hazards. 
Several thousand acres of depauperate, heavy clay or salt-affected soils 
exist on CMR. These soils have low water infiltration rates. Precipita- 
tion on such sites remains on the surface until it evaporates. The soil 
may be completely dry at depths of 6-8 inches below the surface. Range 
sites associated with such soils are referred to as dense clays or 
panspots . 

Soils or land forms present in Class VIII capability (Appendix 7) 
are considered suitable only for recreation, wildlife, or watershed 
uses. Many of these mapping units represent parent materials rather 
than soils. Decomposing sandstone outcrops, Bearpaw shale, beach sand, 
and badlands are included in this category. 

Soils and weathered bedrock on CMR tend to be moderately to highly 
expansive. Not only do these soils swell when wetted, but they also 
heave when excavations are made. 

According to Schmidt (1979), erosion rates on the refuge are high. 
Stock ponds have an average life of about 10 years. The range for 
sediment accumulation in stock ponds in Bearpaw shale drainages (Willow 
Creek) is presently from 0. 1-5.3 acre-f eet/mi^/year . Schmidt stated 

that yields £n other steeply sloping Bearpaw breaks may be as high as 10 
acre-feet/mi /year. The larger figures are as high as those measured 
anywhere in the semi-arid West. He indicated that the distinction 
between natural (geologic) erosion and accelerated (man-caused) erosion 
is not clear. He did state that the occurrence of trenched valley fills 
extending into headwaters, however, presents the likelihood that erosion 
rates were much less in previous times, perhaps prior to large scale 
grazing in the late 1800's. 


38 


Schmidt stated that estimates of bare ground percentages correlate 
more closely with erosion intensity than any other factor identified in 
the literature. Estimates of 340 samples on the refuge revealed average 
ranges of from 15-42 percent bare ground for the potentially best range 
sites . 

Since many of the access roads on the refuge are built on gumbolike 
Bearpaw shale, any measurable precipitation, together with motorized use 
of these roads, is enough to turn them into impassable quagmires. Ruts 
created by vehicles during wet weather often do not heal from one year 
to the next. These ruts then provide channels for water runoff during 
subsequent rainfall, often leading to complete deterioration of the road 
and ultimately necessitating complete regrading of the road system. 

The most conspicuous water areas on CMR are Fort Peck Reservoir and 
the Missouri River. The reservoir and river occupy approximately 
249,000 acres, over 18 million acre-feet of water, when the reservoir is 
at peak storage capacity, maximum pool level of 2,250 feet above msl. 

CMR embraces 35 miles of free-flowing Missouri River upstream of the 
Fort Peck Dam and only one mile below it. The reservoir extends approxi- 
mately 90 miles from east to west. Sediment loads in all streams are 
high as a result of the extremely erosive soils on CMR. 

Ground water is relatively deep in the breaks area and domestic 
wells generally vary from 300-1,200 feet in depth (Table 6). Artesian 
wells can be developed over much of CMR by drilling to the Judith River 
formation. Best quality water is found in wells drilled in the alluvium 
along the Missouri River valley. Good quality water can also be found 
in the Fox Hills-Hell Creek aquifer in Garfield and McCone counties and 
on Harper Ridge where springs are numerous. 

Table 6. Groundwater sources on Charles M. Russell National Wildlife 
Refuge, Montana. 


Source 

Water development potential 

Judith River formation 

Very good 

Bearpaw shale 

None 

Fox Hills sandstone 

Good in upper part where 
topography not greatly 
dissected . 

Hell Creek formation 

Good in lower part where 
topography not greatly 
dissected . 

Fort Union formation 

Poor 

Glacial deposits 

Poor 

A1 luvium 

Fair-go od 


39 


Affected Environment 


Annual runoff f^r CMR is estimated to range 2 from 0.02-0.04 cubic 
feet/second (cfs)/mi /year or 14-29 acre-feet/mi /year. Average dis- 
charge of the Missouri River is 9,288 cfs/year or 0.23 cfs/mi /year. 
However, average discharge is experienced only about 13 percent of the 
time. Flows as low as 0.5 times the mean annual flow occur about 3 per- 
cent of the time, and flows as great as 1.5 times the mean annual flow 
occur about 7 percent of the time (Bureau of Land Management 1979) . 

Past livestock management practices have resulted in development of 
small stock ponds and wells within CMR. These stock ponds are normally 
less than one acre in size and are located near heads of small coulees. 
As discussed earlier, most ponds fill with silt, and a few dams occa- 
sionally fail during heavy runoff. 

WILDLIFE HABITAT-RANGE RESOURCES 


Wildlife habitat was evaluated for representative species during 
summer 1978 on five major vegetative types (Appendix 2). The largest 
type is the sagebrush-gr easewood-grassland , which occupies 61.4 percent 
of the area and includes four subtypes: big sage-grasslands, silver 

sage-bottomlands-sandy uplands, greasewood-grasslands-bottomlands , and 
shadscale-barren areas (Figure 2) . Big sagebrush and greasewood are the 
predominant shrubs, with species such as saltbush, silver sage, rubber 
rabbitbrush, and skunkbrush also present. Important grasses are western 
wheatgrass, needle and thread, green needlegrass, bluegrama, Junegrass, 
Sandberg bluegrass, plains muhly, and bluebunch wheatgrass. The condi- 
tion of big sagebrush and associated shrub and grass species is limiting 
to all wildlife species sampled in this type (Appendix 2). 

The ponderosa pine-juniper type occurs on 35.5 percent of CMR and 
includes three subtypes: ponderosa pine, Douglas fir, and juniper. 

Four coniferous tree species are indigenous: ponderosa pine, Douglas 

fir, limber pine, and Rocky Mountain juniper. Forest communities are 
found on some of the poorer soils. Trees are apparently prevented from 
occupying better sites by competition with grasses for low soil moisture 
(Prodgers 1979) . 

Other major types are grassland-deciduous shrub, riparian-deciduous 
riverbottoms (including ash coulees), and cultivated lands (hayland and 
dryland) . 

Trees, shrubs, and grasses are inadequate for various wildlife re- 
quirements sampled. Security cover for elk is lacking from Timber Creek 
to Fort Peck (Campbell 1979). The interaction of gentle topography, 
roads, and sparse conifer cover creates security cover problems. Mule 
deer require better inters pers ion of trees, sage, and grasses as well as 
more suitable shrubs (big sagebrush, skunkbrush, chokecherry, snowberry, 
rose, serviceberry , and rubber rabbitbrush) and forbs for food. Sharp- 
tailed grouse need 2-3 inches more residual cover (8-10 total) and 
better developed shrub communities (buf faloberry , chokecherry, rose, and 
snowberry) for food and cover. Mountain bluebirds require more nesting 
cavities. Porcupines need denser ground cover and more denning sites. 

The grassland-deciduous shrub community is found in limited areas 
and comprises only 1.8 percent of the land base. It includes shrub 
communities of high importance to wildlife, especially sharp-tailed 


40 










































■ 













' 











County line j 













































































































































Affected Environment 


grouse. In those areas where grassland predominates, the key species 
are perennial grasses such as bluebunch wheatgrass, western wheatgrass, 
and green needlegrass. Prairie forbs include sagewort, wild licorice, 
sunflower, dandelion, yellow sweet clover, vetch, phlox, and prairie 
thermopsis plus many others. Arkansas rose, common snowberry, choke- 
cherry, western serviceberry , and buffaloberry are important shrub 
components of this type. Shrub parameters are better in this type than 
in any other type, but are still inadequate for wildlife (Appendix 2). 

The riparian community comprises only 0.7 percent of the area. The 
major portion of this most productive and important wildlife habitat on 
CMR was permanently destroyed when Fort Peck Reservoir was filled in the 
1940's. Approximately 35 miles of free-flowing river and associated 
habitat still remain on the western portion, subject to flooding and 
numerous ice jams. This flooding causes a change in wildlife habitat 
and associated wildlife-related recreation opportunities. 

Woody plants in the riparian community include four species of 
cottonwood, four species of willow, green ash, box elder, and several 
shrubs also found in the grassland-deciduous shrub type. There are also 
several small stands of quaking aspen in this type. 

Cultivated lands make up 0.6 percent of the area and occur pri- 
marily in the river bottoms in the west half of the refuge and on the 
uplands in the east half of the refuge. Cultivated lands are a mixture 
of small grains (barley and wheat), alfalfa, and wild hay. Cultivated 
lands are considered a major type in this analysis. 

Wildlife habitat in riparian and cultivated types rated higher than 
all other types. Habitat quality for white-tailed deer in these areas 
rated low because browse was limited on minor continuous streams across 
the refuge. 

A variety of other small habitats is represented within and adja- 
cent to the major vegetative areas. Some of these are canyons, bluffs 
or rock outcrops, and ponds, all of which sustain or contribute to a 
variety of plant and animal communities. Pond development is not ex- 
tensive, and the ponds present are in poor condition for wildlife due to 
lack of emergent vegetation and inferior upland vegetation. 

A range survey was conducted on the refuge in 1978 (Fish and Wild- 
life Service 1979) in accordance with the Soil Conservation Service 
(SCS) National Range Handbook. Range sites were identified on the basis 
of soil mapping units, precipitation, and geology (Appendix 8) . Most 
common sites included overflow, sandy, silty, clayey, thin hilly, shallow 
clay, panspots, dense clay, thin breaks, saline upland, shale, and 
badlands. The less common sites included saline lowlands, sands, 
shal low-to-gr avel , shallow, and very shallow. The methodology used in 
the survey is described in Appendix 8. 

After a range site was identified, the plant species present were 
compared with the range site guide criteria for the site at climax to 
obtain range condition. Range condition is the amount of deviation from 
the natural potential or climax. Range condition categories are poor 
(0-25 percent of climax), fair (26-50 percent of climax), good (51-75 
percent of climax), and excellent (76-100 percent of climax). 


42 


Overall results of range conditions found on grazing allotments 
subjected to livestock grazing are excellent, 18 percent; good, 74 per- 
cent; fair, 7 percent; and poor, 1 percent (Appendix 9). 

The survey revealed that range conditions for unallotted portions 
of CMR (no livestock) are predominantly excellent, and areas inaccess- 
ible to livestock by reason of topography or remoteness from water are 
excellent. Areas in fair or good condition are considerably more access- 
ible to livestock. Poor range conditions are typically associated with 
prairie dog towns; locations of prairie dog towns have high correlations 
with past disturbances such as corrals, stock ponds, overgrazed areas, 
or former homesteads and are probably indicators of past use rather than 
causes of current conditions (C. Knowles personal communication). 

On CMR, 10 permittees graze 48 percent of the total active federal 
AUMs, and 48 permittees graze 400 AUMs or less (Appendix 10). Fifteen 
of the 87 operators are dependent on refuge lands for more than 30 
percent of their annual AUM requirements, and 10 operators fulfill 20-30 
percent of their annual needs from refuge lands. The remaining 62 
operators derive less than 20 percent of their annual forage require- 
ments from CMR. 

One of the problems identified during the planning process has been 
the season of livestock grazing use allowed on the refuge. In the past, 
grazing seasons have been established more to reflect the needs of 
operators than to protect natural resources. Currently, 6 allotments 
use rest-rotation systems, 3 use deferred rotation systems, 15 have 
authorized use which encompasses year-long grazing on a portion or all 
of the allotment, and 43 allotments have seasonal grazing (generally 
spring through fall). Livestock allotment boundaries are generally 
fenced on east and west boundaries or have physical barriers which 
preclude livestock movements between allotments. Allotment boundaries 
generally extend north or south off the refuge. The typical situation 
is that adjoining lands off the refuge are included in common allotments 
with CMR lands with no boundary fence separating them. 

WILDLIFE 

At least 45 mammalian species inhabit CMR, ranging from shrews to 
Rocky Mountain elk and bison. However, the only bison maintained are in 
exhibition pastures at Lewistown and Fort Peck; a few stray onto the 
refuge from private ranches in Fergus and Garfield counties. 

Mule deer exceed all other ungulate wildlife in number and dis- 
tribution (Figure 3). In this area they are nonmigratory , using the 
same range the entire year although some local movement occurs with 
seasonal changes in food and range use habits. In the early 1970's, 
mule degr populations dropped dramatically from 10-11 deer to 2-3 
deer/mi (Mackie 1976) ^nd then stabilized; they now appear to be in- 
creasing to 5-6 deer/mi (Montana Department of Fish, Wildlife, and 
Parks 1979) . 

Deciduous river bottoms of the Missouri and Musselshell rivers 
which have not been inundated by Fort Peck Reservoir are inhabited by 
white-tailed deer (Figure 3). Small numbers of white-tailed deer also 


43 


UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 


LEGEND 


CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


MULE DEER HABITAT 

' Overall Distribution 

Primary Known Areas Used During Severe Winters 
• Secondary Known Areas Used During Severe Winters 


WHITE TAILED DEER HABITAT 

^ Overall Distribution 


FIG. 3 

MULE DEER AND WHITE-TAILED 
DEER HABITAT 


MULE DEER 
AND 

WHITE-TAILED DEER HABITAT 






Affected Environment 


occur along the reservoir near the Pines Recreation Area and the Four- 
chette-Telegraph Creek area. 

The last native elk vanished from the breaks around the turn of the 
century. Eighty-one elk were successfully reintroduced in 1951 at three 
locations in Valley and Fergus counties. Another 49 elk were released 
at two locations in Phillips County a year later. Most are now found on 
the north side of the refuge in the breaks (Figure 4); however, some 
expansion of their range to areas south of the Missouri River in Fergus, 
Petroleum, and a portion of Garfield counties has occurred. Further ex- 
pansion in these areas may add an additional 700-900 animals to the herd. 
Adjacent landowners' and grazing permittees' attitudes are negative toward 
this expansion, and poaching and illegal shooting could limit further 
extension of their range. Crop depredations from elk occur on private 
land both within and adjacent to CMR in the northeast. The present elk 
population level in the breaks ecosystem (on and off the refuge) is ap- 
proximately 1,300-1,500. CMR comprises only a portion of the herd's 
habitat. Elk do not recognize the refuge boundary and freely use habitat 
on either side. 

Pronghorns occur sparingly within CMR since there is little suitable 
year-round habitat. However, during severe winter storms, pronghorns and 
mule deer move into the breaks for food and shelter. Concentration areas 
for the severe winters of 1977-78 are shown on Figure 5. 

Sixteen Rocky Mountain bighorn sheep were released in 1947 along 
Billy Creek within a 328-acre fenced enclosure on range formerly occupied 
by Audubon bighorn sheep. In 1951, the herd had grown to 54. In 1952, 
the fence was removed, the animals dispersed, and by 1963, the entire 
population had disappeared, apparently because of poaching, predation, 
disease, and competition with livestock. A second attempt to reestablish 
bighorns in the breaks was undertaken between 1958-61. Forty-three sheep 
were stocked in a 2,200-acre exclosure near the west boundary of CMR 
(Figure 6). The population climbed to 80-100 animals by 1969. Then a 
series of circumstances, including severe winters and competition with 
livestock, decimated the population until only 10-15 animals remained. 
Twenty-seven Rocky Mountain bighorn sheep were released in the Mickey- 
Brandon Buttes area on March 8, 1980. An aerial count in this area 
during November 1983 revealed 57 sheep. 

Black-tailed prairie dogs have been eliminated over much of their 
original range in the western United States. However, 112 widely scattered 
dog towns (Figure 7) occupying approximately 5,240 acres are present on 
CMR. These towns provide all or partial habitat requirements for some 30 
other species of wildlife. 

The rugged breaks, benchlands, and flood plains combine to support 
a large variety of other mammals including bobcats, badgers, coyotes, 
striped skunks, white-tailed jackrabbits, mountain and desert cotton- 
tails, raccoons, porcupines, and numerous small rodent species. Beaver, 
mink, and muskrats occur along the river bottoms and, to a lesser degree, 
along the reservoir shoreline. 

The diverse, avian habitat on the refuge attracts a large variety 
of birds. Over 245 species have been recorded, of which 15 percent are 
year-round residents. Upland sandpipers, mountain plovers, long-billed 


45 


curlews, and burrowing owls are among the more unique birds which inhabit 
the grassy benchlands; burrowing owls and mountain plovers are also 
commonly associated with prairie dog towns. 

Cottonwood trees partly inundated by the reservoir support nests of 
several pairs of osprey as well as rookeries of double-crested cormorants 
and great blue herons. Prairie falcons and golden eagles are common 
nesting residents on cliffs of the more rugged and inaccessible portions 
of the breaks. Two of the prairie falcon nest sites appear to be suit- 
able for cross-fostering of peregrine falcons. 

Very little waterfowl production occurs on Fort Peck Reservoir; 
however, geese concentrate in the safety of several of the bays during 
their molting period, and small flocks of ducks over-winter below the 
dam most years. The largest numbers and varieties of waterfowl occur 
during fall migration when the birds utilize standing grain crops and 
marsh developments along the flood plain for feeding and staging. 

Limited waterfowl production occurs on upland ponds. 

The most common upland game birds are sharp-tailed grouse. They 
occur across CMR in the ecotone between forest and prairie, with woody 
vegetation in the form of shrubs and trees considered an essential 
component of their habitat (Grange 1948). Population estimates for 
sharp-tailed grouse are speculative; one estimate of spring breeding 
bird densities is 5-10 birds/mi (R. Watts personal communication). 

Known dancing grounds are shown on Figure 4. 

Late summer concentrations of nearly 500,000 mourning doves have 
been observed near the Musselshell River bottoms and exposed weedy flats 
along the reservoir on the west side of CMR. Other upland game birds, 
including sage grouse, gray partridge, ring-necked pheasants, and Mer- 
riam's turkeys, occur in varying numbers and locations. 

Several species of nongame birds occur seasonally on CMR. Birds 
considered common and very numerous at one or more seasons include red- 
tailed hawks, marsh hawks, common nighthawks, poorwills, eastern king- 
birds, prairie horned larks, bank swallows, black-billed magpies, pinyon 
jays, American robins, mountain bluebirds, Bohemian waxwings , house 
sparrows, western meadowlarks, yellow-headed blackbirds, red-winged 
blackbirds. Brewer's blackbirds, lark buntings, American goldfinches, 
and chipping sparrows. 

The CMR fishery resource is limited to Fort Peck Reservoir, the 
Dredge Cuts, the Missouri River above the reservoir and below the dam, 
Musselshell River, and stocked ponds (Alvord 1979). Common sport fish 
include northern pike, walleye, lake trout, shovelnose sturgeon, sauger, 
burbot, paddlefish, and channel catfish. Pallid sturgeon are present in 
small numbers and have been called a threatened species by the American 
Fisheries Society (Alvord 1979) . They have not been so classified by 
the Secretary of the Interior. A commercial fishery exists on the 
reservoir involving goldeye, carp, river carpsucker, buffalo, and fresh- 
water drum. 

Fisheries management is confined primarily to stocking operations 
from state and federal hatcheries and enforcement of regulations. In 
addition, ongoing studies and research by MDFW&P are defining require- 
ments for paddlefish spawning; significant walleye spawning runs up Big 
Dry Creek have been documented (R. Johnson personal communication) . The 
CMR fishery is limited by siltation of the lake and fluctuating water 


46 


UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 

CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


LEGEND 


ELK HABITAT 

\\ Overall Distri bution 
y\ ^ Occasional Winter Distribution 
// 11 ^ Normal Winter Distribution 


SHARP TAILED GROUSE HABITAT 

;X\\; Overall Distribution 
• Dancing Grounds 

Excellent Deciduous Shrub Habitat 


I 



FIG. A ELK HABITAT AND 
SHARP-TAILED GROUSE HABITAT 


ELK HABITAT 
AND 

SHARP-TAILED GROUSE HABITAT 








UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 

CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


PRONGHORN HABITAT 
AND 

SAGE GROUSE HABITAT 


LEGEND 

PRONGHORN HABITAT SAGE GROUSE HABITAT 

° V " a " Dls, ' lb b"°n ///// Overall Distribution 

_ wmter Distribut.on Winter Distribution 

H « s ' ,ver Sage Bolloms Usoil Only During Severe = * , _ „ . 

,5 ^ Silver Sage Bolloms Used Only During Severe 
Winters: Outside Normal Overall Distribution ... _ 

Winters. Outside Normal Overall Distribution 

• Strutting Grounds 



FIG. 5 

PRONGHORN HABITAT AND 
SAGE GROUSE HABITAT 





































UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 

CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


LEGEND 

BIGHORN SHEEP HABITAT 

Overall Distribution 
Winter Distribution 
Critical Winter Distribution 
^ Possible Introduction Sues 



FIG. 6 BIGHORN SHEEP HABITAT 
















UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 


LEGEND 


CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


* Prairie Dog Town 



FIG. 7 PRAIRIE DOG TOWNS 












































































Affected Environment 


levels which makes establishment of littoral zone vegetation needed for 
spawning habitat almost impossible. This problem is compounded by "Fort 
Peck being the first mainstream reservoir on the Missouri which makes it 
difficult to control water levels. Due to these limitations, there is 
little that can be done to improve the current fishery management pro- 
gram. Small intermittent and continuous streams may provide spawning 
and nursery habitat. However, no information is available on these 
streams . 

Six species of amphibians and ten reptiles are known to occur in 
eastern Montana with ranges overlapping CMR. None of these species is 
endangered or threatened and none has commercial value. 

Peregrine falcons often winter in the vicinity of Fort Peck where 
they prey on winter flocks of ducks and other birds. Occasional sight- 
ings have also been made at the west edge of CMR. Migrating bald eagles 
rest along the shoreline of Fort Peck Reservoir as well as along the 
Missouri River. One nest is thought to have been built in 1966 along 
Two Calf Creek where it joins the Missouri River (C. Jones personal 
communication). In 1967, a black-footed ferret survey reported ferret 
sign on two prairie dog towns although no ferrets were observed (For- 
tenbery 1967) . 

No endangered or threatened species of plants are known to occur on 
CMR (K. Lackshewitz personal communication). However, the refuge may be 
within the geographical distribution of Rorippa calycina , a species of 
watercress classified as potentially threatened or endangered in Mon- 
tana. 

RECREATION AND CULTURAL RESOURCES 


Within a 150-mile radius of CMR, there are numerous competing rec- 
reation resources which constitute a significant array of sites and 
areas available to the public (Table 7). Because they are so extensive 
in size and located in a lightly populated section of the country, they 
generally receive only limited use. In addition, there are many hiking 
and jeep trails, ghost towns, state parks, wildlife areas, and other 
recreation opportunities available to the public that tend to compete 
with similar opportunities available on the refuge. 

Major recreation attractions on CMR include the 249,000-acre Fort 
Peck Reservoir and the scenic segment of the Upper Missouri National 
Wild and Scenic River administered by BLM. A designated national 
wilderness area is located at UL Bend, and fifteen additional wilderness 
areas comprising about 161,000 acres have been proposed for inclusion in 
the National Wilderness Preservation System and are awaiting Congres- 
sional action. 

Considering its vast size, CMR contains relatively few developed 
recreation areas. Most of these are COE areas located in the vicinity 
of Fort Peck Towns ite and the Big Dry Arm of the reservoir. Three state 
parks are administered by MDFW&P. FWS manages the bulk of undeveloped 
lands on CMR. The only developed recreation areas administered by this 
agency are a wildlife tour route, boat access sites, and a wildlife 
display pasture at Lewistown. 


51 


Table 7. Competing recreation resources on and within 150 miles of 
the Charles M. Russell National Wildlife Refuge, Montana. 


Area name 


Distance from 
CMR (miles) 


St at e/county /province 


Ackley Lake 
Bear tooth Game Range 
Benton Lake National Wildlife Refuge 
Bighorn Canyon National Recreation Area 
Bowdoin National Wildlife Refuge 
Canyon Ferry Reservoir 
Custer National Forest 
Deadman’s Basin Reservoir 
Freezeout Lake Game Management Area 
Fresno Reservoir 
Gallatin National Forest 
Gates of the Mountains Wilderness Area 
Helena National Forest 
Holter and Hauser lakes 
Lake Francis Recreation Area 
Lake Mason, Halfbreed and Hailstone 7( 

National Wildlife refuges 
(satellites of CMR) 

Lewis and Clark National Forest 
Lewis and Clark National Historic Trail 
Martinsdale Reservoir 

Medicine Lake National Wildlife Refuge 
Medicine Rocks State Park 
Missouri River above Fort Benton 
Nelson Reservoir Recreation Area 
Smith River 

Tiber Reservoir Recreation Area 
Tongue River 

Upper Missouri National Wild C 

and Scenic River 
Upper Musselshell River 
Yellowstone River 

Headwaters of Lake Sakajawea 

Lewis and Clark National Historic Trail 

Theodore Roosevelt National Memorial Park 

Cypress Hills Provincial Park 
Prairie Grasslands National Park 
(proposed) 


70 

Montana 
Judith Basin 

130 

Lewis and Clark 

90 

Cascade 

150 

Bighorn 

50 

Phil lips 

150 

Broadwater, Lewis 

110 

Various counties 

100 

Golden Valley 

150 

Teton 

70 

Hill 

110 

Various counties 

150 

Clark, Meagher 

110 

Various counties 

150 

Lewis and Clark 

130 

Pondera 

110 

Various counties 

70 

Vf II 

90 

II II 

Meagher, Wheatland 

90 

Sheridan, Custer 

100 

Carter 

80 

Various counties 

60 

Phil lips 

110 

Meagher, Cascade 

100 

Toole, Liberty 

70 

Rosebud, Bighorn 

140 

Various counties 

150 

II II 

80 

II II 

130 

North Dakota 
Williams, McKenzie 

110 

Williams, McKenzie 

140 

McKenzie, Billings 

140 

80 

Saskatchewan (Cana< 


& Clark 


Source: Montana Department of Fish and Game 1978, North Dakota State 

Outdoor Recreation Agency 1975, Saskatchewan Tourism and Renewable 
Resources 1977. 


52 


Affected Environment 


Private cabins are located at four areas on federal land. At 
present there are 428 lots, 337 of which currently have structures on 
them. These sites are leased by COE to private individuals. Figure 8 
shows existing recreation facilities. 

An estimated 357,000 visitor days of use occurred on CMR in 1978. 

Based on information provided by BLM, the scenic river segment of the 
Upper Missouri National Wild and Scenic River within the refuge provided 
about 2,500 floater days of this use (W. Cutler personal communication). 
Based on a preliminary survey conducted on the refuge in 1978, 91 per- 
cent of visitors were Montanans (Fish and Wildlife Service 1978). Approxi- 
mately 75 percent of the visitation to CMR originated within a 150-mile 
radius; 20 percent of the visitors came from places between 150-500 
miles distant; and the remaining 5 percent originated from points 
beyond . 

CMR is open to camping for two continuous weeks at any one location 
within any 30-day period. Fishing and hunting, together with other 
wildlife-related activities, are permitted on the refuge. Hunting is 
permitted, except in certain areas, for elk, mule and white-tailed deer, 
pronghorns, waterfowl, sage grouse, sharp-tailed grouse, gray partridge, 
ring-necked pheasants, and turkeys under state and federal regulations. 

In 1979, free elk permits for archery hunting were required for the 
first time. The harvest of game animals in 1979 included 150 elk by gun 
and 70 by archery, 400 deer by gun and 30 by archery, 7 turkeys and 55 
pronghorns (Fish and Wildlife Service 1979) . Waterfowl and upland game 
hunting was considered light. Trapping is currently allowed only as needed 
to protect resource values. However, a limited trapping program is being 
considered starting with the 1984-85 trapping season. 

Among the most popular activities on the refuge in 1978 were view- 
ing scenery and exhibits, followed by picnicking, fishing, power boating, 
and camping (Table 8) . The methodology used in estimating visitor use 
is explained in Appendix 17. 

Recreation use is concentrated at a few locations on the refuge due 
to a lack of good roads and access to recreation areas which prevent 
people from fully utilizing the resources. The boating potential on 
Fort Peck Reservoir has not been realized (Montana Department of Fish 
and Game 1978). 

Because livestock occur near public use areas, there are isolated 
instances of minor conflicts with recreationists, such as the presence 
of animals and their feces in camp-picnic areas, temporary blocking of 
roads by small herds of cattle, and spooking of game during the hunting 
season. Visitors passing through the refuge usually see more livestock 
than wild animals. 

There generally have been increases in participation for all recrea- 
tion activities in those portions of Montana, North Dakota, Saskatchewan, 
and Alberta within a 150-mile radius of the refuge. In other areas, 
some of these activities show decreases, such as horseback riding on 
trails, hunting for white-tailed deer and pronghorns, and ice fishing. 


53 


Table 8. Estimates of current visitation on Charles M. Russell 
National Wildlife Refuge, Montana. 


Visitation type 

FWS 

Visitor days (000 f s) 

BLM/COE/State 1978 


1978 

1978 Totals 


Wildlife related 


Cultural studies 

k 

- 

k 

Environmental education 

* 

- 

k 

Interpretation 

Viewing scenery-exhibits 

12 

92 

104 

Recreation 

Hunting 

10 

2 

12 

Fishing 

5 

46 

51 

Nature observation 

o 

J 

- 

3 

Wildlife photography 

2 

- 

2 

Backcountry travel (motor) 

1 

- 

1 

Backcountry travel (nonmotor) 

k 

- 

* 

Nonwildlife related 
Recreation 

Camping 

13 

19 

32 

Picnicking 

2 

75 

77 

Beach swimming 

3 

12 

15 

Powerboating 

6 

32 

38 

Nonpowerboating 

1 

5 

6 

Waterskiing 

1 

10 

11 

Backpacking -hiking 

k 

- 

k 

Visiting special sites 

1 

- 

1 

Horseback riding 

k 

- 

* 

Other 

2 

- 

2 

Totals 

64 

293 

357 


*Less than 1,000 visitor days. 


Recreation needs generally rank lowest in that area immediately 
surrounding the refuge on the north and east. This is explained by the 
lack of major urban centers there, compared to those areas in the south 
and west where the larger cities of Billings and Great Falls are located. 
In the latter areas, activities for which needs are most critical include 
nonurban swimming, horseback riding, and backpacking. In the small part 
of North Dakota lying within the 150-mile radius of the refuge to the 
east, needs have been identified for such activities as picnicking, 
beach swimming, and boating (Montana Department of Fish and Game 1978, 
North Dakota State Outdoor Recreation Agency 1975, Saskatchewan Tourism, 
and Renewable Resources 1977). No information was available on recrea- 
tion needs for Alberta and Saskatchewan. 


54 


UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 


LEGEND 


CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


EXISTING RECREATION RESOURCES 


O FWS Headquarters 

Corps of Engineers Headquarters 
O Corps of Engineers Recreation Area 

O 




Montana Department of Fish. Wildlife and Parks 
Recreation Area 


FIG. 8 EXISTING RECREATION 
RESOURCES 


• Research Natural Area 

Upper Missouri National Wild and Scenic Riv 

1 UL Bend Wilderness ( Existing ) 

Proposed Wilderness Areas 
O Boating Access ( FWS ) 

Fishing Access ( FWS ) 

® National Historic Site 














































































































































































































































Affected Environment 


Proposed energy development in Eastern Montana could greatly in- 
crease the demand for recreation, while increasing gasoline prices could 
decrease recreation use on the refuge. No information is available on 
either of these items. 

Many cultural sites appear to be significant in the history or 
prehistory of the refuge. Sites that have been identified include camp- 
sites, tipi rings, stone effigies, bison fill sites, homesteads, historic 
graves, and early townsites. A total of 153 sites, 87 historic and 66 
archeological, have been identified, many of which have not been for- 
mally recorded. Of these, three historic sites have been found eligible 
for or placed on the National Register: Rocky Point Townsite, and 

Lewis and Clark campsites of 23 and 24 May, 1805. 

In addition, there are two existing national natural landmarks 
(Hell Creek and Big Creek) and four research natural areas. 

SOCIOECONOMICS 


The region around CMR which includes the counties of Fergus, Gar- 
field, McCone, Petroleum, Phillips, and Valley, has been characterized 
by relatively slow economic growth with an economy based on the produc- 
tion of grain and livestock. Following a regional trend, the number of 
agricultural operations has decreased while their size and value has 
increased. Most agricultural products are marketed outside the area. 

Farming is the largest single income producing sector of the six- 
county regional economy (Appendix 11). Gross income from this sector in 
1975 amounted to $70.9 million and represented about 42 percent of the 
total income. Government led the nonfarm industries as a source of 
income followed by wholesale and retail trade, services, and contract 
construction. Range livestock-related earnings for the region averaged 
$50.8 million annually between 1970-75, based on a supply of about 
599,200 animals (sheep and cattle). A total of about 6,050,860 AUMs is 
required to sustain this livestock base (Bureau of Land Management 
1979) . 

Total regional income from all sources was $166,922,000 in 1975, 
compared to $101,694,000 in 1970 (Table 9). Data indicate that five of 
the six counties, (Petroleum County excepted), had per capita income 
greater than the Montana average in 1974 (Table 10). Also, growth in 
per capita income for 1969-74 in the region was significant relative to 
per capita income growth in the United States as a whole. 

Between 1960-70, employment decreased in the region (Appendix 12). 
However, since 1972, all counties have experienced increases in the 
number of persons employed over 1970. The unemployment rate increased 
an average of 4.6 percent from 1972-77, considerably below the statewide 
unemployment rate of 5.8 percent for December 1977. 

Based on a preliminary survey of visitor use, costs of goods and 
services purchased by visitors to CMR totaled about $32/person (Fish and 
Wildlife Service 1978). Assuming these costs are representative for the 
357,000 visitors who came to CMR, about $11.4 million was injected into 
the economy for food, lodging, gasoline, and related items. 


56 


Table 9. Farm income data for a six-county region at Charles M. Russell 
National Wildlife Refuge, Montana. 


County 

Total 

income 

1970 

farm 
( $000* s) 
1975 

Total non-farm 
income ($000' s) 
1970 1975 

Total income 
($000 , s) 

1970 1975 

Fergus 

$ 9,638 

$16,722 

$21,092 

$32,703 

$ 30,730 

$ 49,425 

Garf ield 

4,277 

7,093 

1,657 

2,658 

5,934 

9,751 

McCone 

4,319 

11,196 

3,632 

7,222 

7,951 

18,418 

Petroleum 

1,650 

178 

658 

882 

2308 

1060 

Phil lips 

10,376 

13,478 

6331 

10,955 

16,707 

24,433 

Val ley 

12,699 

22,267 

25,365 

41,568 

38,064 

63,835 

Six-county 

total 

$42,959 

$70,934 

$58,735 

$95,988 

$101,694 

$166,922 


Source: Montana Department of Community Affairs 1978. 


Table 10. Comparative 1974 per capita income for a six-county 
region at Charles M. Russell National Wildlife Refuge, Montana. 


County-state 

Per capita 
income 

Average annual 
increase 1969-74 (%) 

Fergus 

$4,722 

11.4 

Garf ield 

4,449 

11.9 

McCone 

6,801 

16.2 

Petroleum 

3,751 

9.4 

Phillips 

4,413 

12.2 

Val ley 

4,681 

12.6 

Montana 

4,347 

9.6 

United States 

$4,572 

7.6 


Source: Bureau of the Census 1977. 


57 


Affected Environment 


Table 10a. Charles M. Russell National Wildlife Refuge Study, Region 
and the Montana Economy (Fergus, Garfield, McCone, Petroleum, Phillips, 
and Valley counties, Montana) 


Date 

Employment 

Income^ 

Average Income^ 

1970 

4,150 

$17,780,000 

$4,284 

1975 

5,503 

$37,288,000 

$6,776 

1977 

5,552 

$42,794,000 

$7,708 

State of Montana 



1977 

175,652 

$1,702,903,000 

$9,695 


Source: County Business Patterns - Montana, Table 2, Counties - 

Employees, Payroll, and Establishments, by Industry: 1977 


The installed electrical generation capacity of Fort Peck Dam and 
powerplant totals 165,000 KW. The reservoir now produces over $13 
million in average annual benefits derived from power production, flood 
control, navigation, irrigation, rentals from leasing of land, and 
recreation at COE areas (Corps of Engineers 1977). 

Under provisions of the Refuge Revenue Sharing Act of 1978 (Public 
Law 95-469), as amended, payments are made to local governments. A 
total of $15,133.54 was distributed to the six counties in the CMR 
region in fiscal year 1978 under terms of this Act (Fish and Wildlife 
Service 1978) . 

In 1979, 67 grazing allotments (Figure 9) were partially or totally 
located on CMR; 87 individuals, companies, or associations grazed live- 
stock on the refuge. CMR records for that year indicate 60,108 federal 
livestock AUMs were authorized on the refuge, with 3,584 federal AUMs in 
a nonuse status, and 56,524 federal AUMs representing actual use. 

Private and state AUMs totalled 12,135 within the refuge boundary. 

Federal grazing fees were $1.89/AUM in 1979. The 56,524 AUMs of 
grazing on federal range represented $106,830 in revenues paid to the 
United States Treasury. 

MDSL has a sliding scale for determining the amount paid per AUM on 
state land. This is based upon the carrying capacity of a given parcel 
for the grazing season. The rates for less than 14 head/section are 
$3.54/AUM, for 14-19 head, $3 . 64/AUM, and over 19 head, $3.74/AUM. Most 
of the state lands on CMR fall in the "under 14 head" category (G. 
Brandenburg personal communication) . AUMs in Montana on private rental 
lands were a minimum of $8.40/AUM in 1979 (Economic, Statistics and 
Cooperative Service 1979). 

In 1979, approximately 800 acres of CMR were farmed. This con- 
sisted of about 70 acres of grain, 450 acres of hay, and 280 acres of 
dense nesting cover. FWS's share was 20 acres of grain crops, 20 acres 
of hay, and 280 acres of dense nesting cover. No data are available on 
income derived by the eight cooperators from the crops they produced. 


58 


The CMR area is rural and sparsely populated. CMR occupies por- 
tions of six counties which had a 1970 population of about 34,000 
(Table 11) and a 1975 estimated population of approximately 36,500. 

Three towns adjacent to CMR and their 1970 populations are Glasgow, 20 
miles north (population 4,700); Lewistown, 65 miles southwest (popula- 
tion 6,437); and Malta, 69 miles north (population 2,195). Several 
other smaller towns and villages border the area. 

As with most rural areas in the United States, there was a general 
population decline in the six Montana counties contiguous to CMR from 
1960-70. In the period 1960-70, while the population in Montana as a 
whole was increasing by nearly 3 percent, these counties decreased by 
nearly 28 percent. However, from 1970-75, this trend was at least 
temporarily reversed because population in the six-county area increased 
by 7 percent. 

Population growth for the area within 150 miles of the refuge, ex- 
cluding Canada, is expected to increase by about 85,000 people between 
1978-2000 (Montana Department of Community Affairs 1978, Murdock and 
Ostenson 1976). Potential energy developments, especially coal, could 
significantly impact population growth. However, the magnitude of this 
impact is presently unknown. 

The age distribution of people residing in the region is comparable 
to that of Montana as a whole. Compared to the state, the region has 
approximately half as many physicians per person; two counties have no 
physicians. Only 5 percent of Montana’s population resides in the six- 
county CMR region, making this a comparatively undeveloped area with few 
of the major problems faced in rapidly growing regions. 

The general decline in regional population parallels a similar 
decrease in the number of farms between 1969-74. Although the region is 
still predominantly rural, it seems there is a trend toward urbanization. 

Median family income for the region in 1970 averaged about $900 
less than for the state, and the number of families classified at the 
poverty level was higher in the region. Those who continue to farm need 
more land than previously to maintain their standard of living. 

Approximately 7 percent of the property valuation and 6 percent of 
the taxable valuation in Montana is located in the six-county CMR 
region. Most of this value is associated with Fergus and Valley coun- 
ties where more than half thd regional population is concentrated. 

Nearly 6 percent of the 1974 property taxes in Montana were paid by 
residents of the region where only 5 percent of the population lives. 

This is indicative of the higher per capita taxation in the region, 
which was slightly more than $150 higher per person than for the state. 

Public opinion surveyed at the state level tends to be conserva- 
tive, as it relates to social and cultural attitudes. Billings (1977) 
noted, "...Montana’s game animals are an acknowledged resource for 
residents and non-residents, and for hunters and general observers. 

Over 55 percent of the men and over 20 percent of the women in Montana 
claim to be hunters, and fewer than one in seven oppose hunting. Whether 
they hunt or not, approximately 70 percent of Montana's residents make 
special efforts to observe wildlife in its natural setting.” 

Comments received at public meetings, through correspondence and 
personal contacts conducted as part of the overall planning effort, 
covered the full range of management interests, from protection and 


59 


Table 11. Demographic data for counties contiguous to Charles M. Russell National Wildlife 
Refuge, Montana. 


Affected Environment 


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60 









































































































UNITED STATES DEPARTMENT OF THE INTERIOR 
FISH AND WILDLIFE SERVICE 

CHARLES M. RUSSELL 
NATIONAL WILDLIFE REFUGE 
ENVIRONMENTAL STATEMENT 


GRAZING ALLOTMENTS 

Note Allotment boundaries generally fenced or have physical 
barriers which separate them. 


LEGEND 

GRAZING ALLOTMENTS 


Number and Name 

1 Antelope Creek 

2 E Slippery Ann 

3 Rock Creek 

4 Nichols Coulee 

5 Beauchamp Creek 

6 Fourchette Creek 

7 N Hawley Creek 

8 Telegraph Creek 

9 UL Bend 

10 Box Elder ft 3 

11 Box Elder 

12 Kill Woman 
Larb Hills 
Carpenter Creek 
Cabin Coulee 
7 Point 


17 Silver Dollar 

18 Skunk Coulee / Mud Creek 

19 Duck Creek 

20 Fort Peck Common 
21 Bear Creek 

22 Bobcat Creek 

23 Spring Creek 

24 Sand Arroyo / Rock Creek 

25 Rock Creek 

26 Bug Creek 

27 Nelson Creek 

28 Pine Coulee 

29 Big Dry 

30 Snap Creek 

31 Lone Tree 

32 Coyote Basin 


















































































































































































































































































Affected Environment 


proper management of wildlife to management of CMR primarily for live- 
stock. Individuals who rely on livestock grazing for a living favored 
multiple use of the refuge and minimum interference by government in 
cattle operations as historically practiced. In contrast, those sensi- 
tive to wildlife favored management of CMR primarily for wildlife. 
Special interest groups representing agriculture generally preferred to 
include livestock interests on a planning and advisory board for CMR and 
to continue grazing as in the past. Those who represented wildlife 
interests preferred habitat preservation for wildlife through appro- 
priate restraints such as conservative grazing by domestic livestock. 
Others wanted no grazing, hunting, or roads; still others wanted mass 
recreation and development. 


62 
































































































































IV. ENVIRONMENTAL CONSEQUENCES 





IV. ENVIRONMENTAL CONSEQUENCES 


This chapter analyzes the significant environmental effects of the 
five alternatives discussed in Section II. The five elements or manage- 
ment actions common to all alternatives, which may significantly affect 
the environmental quality of the refuge, are endangered and unique 
species introduction, wildlife habitat management, recreation and cul- 
tural resources management, forage allocation, and range developments. 

The following basic assumptions were made for all alternatives to 
facilitate analysis: 

1) The chosen alternative would be implemented if adequate funding 
and manpower are made available. 

2) After a management plan is selected, actions that are implemented 
would be monitored. Necessary adjustments would be made to correct 
those actions that are not meeting objectives. 

3) Short-term impacts are those which would occur during implementa- 
tion, approximately 1985 through 1990; long-term impacts are those 
projected to exist when the wildlife objectives are met (i.e. by 
the year 2005 or later). 

4) Unauthorized human and livestock use would be strictly controlled 
under each alternative and would not be a significant factor affect- 
ing environmental quality. 

5) Because habitat is recognized as the key to wildlife abundance, 
this document emphasizes habitat quality and quantity rather than 
wild animal population numbers or densities. Where possible, 

the habitat capability to support numbers of animals per unit area 
have been used. Establishment of high quality habitat will provide 
adequate populations of wildlife species within constraints imposed 
by drought, severe winters, disease, and other variables which are 
largely uncontrollable. 


63 


Consequences 
No Action 


ALTERNATIVE A 
(No Action) 


SOILS-WATERSHED 


Habitat management to control all burning would result in conif- 
erous communities proceeding to climax and could increase the potential 
for destructive wildfires. If areas were burned, it could result in 
temporary loss of vegetative cover, increased runoff, and soil loss 
until vegetation is restored. In favorable years, fall "green-up" can 
occur and eliminate erosion problems on areas burned the preceding 
summer. Once herbaceous vegetation is restored, erosion would probably 
be reduced below levels associated with the coniferous forest communi- 
ties. Eichhorn and Watts (1974) observed that erosion potential was less 
for coniferous forest sites that had been burned and replaced with a 
grassland community as compared to forested communities with their 
sparse understory vegetation. 

Grazing patterns would not significantly change present ranges of 
bare ground (60-75 percent) on marginal breaks, badlands or shale areas, 
or those ranges (20-42 percent) presently existing on better quality 
clayey, sandy, or silty range sites. However, a present slight upward 
trend in range condition would provide for some increased plant and 
litter cover over the refuge as a whole by the year 2000. This would 
provide a slight enhancement to soil productivity and watershed quality 
as compared to present conditions. 

Livestock concentration areas, particularly around watering areas, 
would continue to exhibit soil erosion and watershed quality problems 
because of poorer range conditions and trampling effects. Marginal 
sites that are highly fragile, such as thin breaks, badlands, and shale, 
would receive some livestock use under this alternative. Any use on 
these areas by livestock tends to increase soil or parent material loss 
because of vegetation cover removal and livestock movements (W. Larsen 
personal communication) . Poorly located reservoirs would continue to 
silt-in at accelerated rates. Lusby (1970) found that runoff rates on 
Mancos shale derived soils, which react much like Bearpaw shale, averaged 
30 percent less on ungrazed watersheds versus grazed watersheds, and 
sediment yields were about 45 percent less. His studies indicated that 
runoff was directly related to the percentage of bare soil on the water- 
shed, with hydrologic changes caused by the trampling of livestock on 
soil loosened by frost heavings. 

Although refuge-wide range condition shows a slight upward trend 
which would bring some long-term increase in productivity, short-term 
enhancement would be minimal. Soil lost as a result of accelerated 
(man-caused) erosion would be a long-term impact and an irretrievable 
loss . 


64 


WILDLIFE HABITAT-RANGE RESOURCES 


Fire management would involve suppression of all wildfires. There 
would be no prescribed burning or "let-burn" philosophy. This could 
reduce the extent of several communities and eventually the diversity of 
wildlife habitat. The existing fisheries management program would 
result in no significant environmental impacts. 

Wildlife habitat would not change substantially under the No Action 
alternative. Lack of residual cover and shrubs would remain as major 
problems. Wildlife population levels would remain about the same also. 

Bighorn sheep habitat would be adversely affected due to grazing by 
cattle on winter range near Two Calf Creek (Constan 1978). Continued 
competition with livestock and periodic severe winters would keep sheep 
at low numbers and preclude any effective management program. 

Sharp-tailed grouse habitat would remain in fair condition. 
Eighty-one percent of all samples taken in the 1978 survey indicated 
sharp-tailed grouse lack 8-10 inches of residual cover required for 
successful nesting (Christenson 1971, Sisson 1976). Habitat to support 
5-10 birds/mi would be maintained. 

The quantity and quality of forbs would be limited. Insufficient 
forb productivity occurred on 46 percent of the areas sampled for prong- 
horns, and 65 percent of the areas sampled for mule deer. They feed on 
such plants from spring to late summer (Mackie 1970, Hoover et al. 1959, 
Cole and Wilkins 1958). 

Vegetation around ponds would remain inadequate to provide nesting 
cover for waterfowl. Bent (1923), Bennett (1938), Burgess et al. 

(1965), and Drewien and Springer (1969) stated vegetation less than 1.5 
feet tall and covering less than 75 percent of the ground is inadequate 
for nesting waterfowl. The Creston Valley Wildlife Management Authority 
(1974) cited several studies which correlated high waterfowl nesting 
densities and success rates with undisturbed stands of vegetation 
(Nelson 1972, Schranck 1966, Bue et al. 1952, Keith 1961). On 89 per- 
cent of the CMR ponds sampled in 1978, herbaceous upland vegetation was 
less than one foot tall and had less than 69 percent ground cover (Fish 
and Wildlife Service 1978). Grazing by livestock has resulted in less 
than optimal waterfowl habitat conditions on many potentially suitable 
ponds on CMR. 

Rodents lacked sufficient cover on 79 percent of sites sampled, 
and this condition would persist. This would lower quality of hunting 
habitat for raptors and terrestrial carnivores. 

Trampling and consumption of desirable browse species would be 
extensive; 75-90 percent of all areas sampled for habitat quality had 
inadequate browse (Fish and Wildlife Service 1978). Several livestock 
allotments on the Big Dry Arm demonstrate the effects of substantial 
livestock grazing, which has resulted in poor browse communities. Other 
allotments in this area that have experienced light or no livestock use 
in recent years have well developed browse communities. A static or 
downward trend in these communities would continue, meaning inadequate 
food and cover for sharp-tailed grouse and mule deer which rely heavily 
upon hardwood draws for portions of their life requirements (Severson 


65 


Consequences 
No Action 


1966) . This would help hold the sustained deer habitat capability at 
the estimated level of 5-6 deer/mi . The present browse communities 
would probably not experience the slight upward trend in condition that 
the refuge as a whole would experience. Shrub communities would continue 
to receive a disproportionate amount of livestock use, which would be 
reflected by static or deteriorating conditions. 

Dense stands of big sage are lacking on 67 percent of the sagebrush 
areas sampled. These food and cover requirements are needed for prong- 
horns and sage grouse (Bayless 1969, Wallstead 1971, Klebenow 1969). 

This is especially true in Garfield and McCone counties and the central 
Phillips County portion of CMR, which contains the primary range for 
pronghorns. Silver sage, a prime winter food for pronghorns (D. Pyrah 
personal communication, Cole and Wilkins 1958), is lacking in the 
central Phillips County area. Livestock use under No Action would tend 
to perpetuate or expand the existing sagebrush flat areas by their use 
patterns (Kindschy 1977). Moderate to heavy livestock grazing during 
spring and summer favors shrubs such as big and silver sage at the 
expense of more palatable grasses and forbs (Smith 1979). The expected 
result would be to benefit the present sagebrush communities because of 
present use patterns by livestock. Although range conditions may be 
actually lowered in these areas, some habitat enhancement for such 
species as pronghorns and sage grouse could be expected because of 
possible sagebrush expansion. 

Security cover for elk in the form of dense canopies of ponderosa 
pine, juniper, and pine-juniper (Campbell 1978) would continue to be in- 
adequate on the north side of the reservoir. This lack of security 
cover plus the presence of numerous roads and their associated vehicular 
traffic causes elk to widely disperse during the hunting season, and 
some animals do not return. Herds would remain at their current size of 
1,300-1,500 over-wintering animals. The presence of numerous roads for 
which no adequate control of access exists would continue to lower 
habitat values for elk and deer. Perry and Overly (1977) found that 
roads, and disturbances associated with roads, exerted a considerable 
influence on elk and deer use of habitat. Elk use was reduced by 95 
percent and deer use by 100 percent under the most extreme case studied, 
which was a "main road" in a meadow situation. The lack of dense tree 
stands also means lack of thermal cover (Forest Service 1977). 

The riparian areas along the Missouri River would be maintained for 
white-tailed deer through maintenance of present fences. These areas 
are in good condition and would remain in about the same condition (Fish 
and Wildlife Service 1978). 

Minor riparian areas along continuous and intermittent streams 
across the refuge are not fenced, and thus are accessible to cattle. 

This would perpetuate the existing poor deciduous browse conditions for 
wildlife. Severson and Boldt (1978) indicated livestock use in shrubby 
draws results in lack of shrub production because of tight sod-bound 
soil, lower moisture infiltration, and higher soil temperatures. 

Off-refuge impacts associated with No Action would be minimal. 
Habitat quality for wildlife would probably remain unchanged as a result 
of maintaining present livestock levels on the refuge, and wildlife 
objectives would not be met. 


66 


Coyotes can cause significant economic loss to ranchers. Removal 
of the individual animals responsible for the damage would eliminate or 
reduce the problem and have no lasting effects on predator populations. 
Avoiding control of prairie dogs or other small mammals would allow 
healthy, productive populations of prairie dogs and 30+ species asso- 
ciated with them. It would preclude any possible killing of black- 
footed ferrets. 

The effect of coyote depredation on deer populations appears to be 
relative to moisture conditions and rodent levels (Dood 1978, Pyrah 
1979). Dood’s work in the Missouri River breaks indicated that fawn 
mortality was related to habitat use in the summer months. When pre- 
cipitation was adequate to keep forbs green, does and their fawns used 
open habitat types. When moisture was inadequate, forbs dried up and 
does moved with their fawns into heavy timber types to use browse. 

Coyote depredation on fawns was higher when fawns were in the open types 
in all cases. Work by Pyrah showed that deer mortality from coyote 
depredation was less in two very severe winters as opposed to two normal 
or open winters. He correlated the lighter mortality in the severe 
winters with high-small mammal populations versus greater mortality in 
normal winters with low-small mammal populations. Coyotes preyed 
heavily on the small mammals and less so on the deer. 

Inability to predict adequate moisture levels or rodent populations 
which affect coyote depredation on deer makes it difficult to predict 
the level or extent of depredation in any given year. 

Continuation of present forage allocations would maintain lower 
than desired levels for wildlife habitat quality. Competition between 
wildlife and livestock for security cover and choice feeding sites would 
continue at present levels. Mackie (1970) observed that numbers and 
management of livestock should be considered on the basis of forage 
available on primary range areas rather than on the entire area. Live- 
stock would be allocated forage on the basis of the entire area under 
this alternative. An examination of the 1952-53 range survey summary 
for the refuge revealed that wildlife are presently primarily allocated 
forage on Class VIII lands which are unsuitable for livestock use and 
suitable only for watershed, recreation, and wildlife values. The forage 
on the best areas was allocated almost solely to livestock. 

Forage allocations would continue to be dominantly in favor of 
livestock. A slow upward trend in condition would occur over about 75 
percent of the refuge. This trend would continue and would be expected 
to raise range conditions to excellent on 20 percent of the grazed 
portion of the refuge by the year 2000 (compared to the present level of 
18 percent) . Some range deterioration would continue as a result of 
overstocking on some allotments, especially in the Big Dry Arm portion 
of the refuge. About 10 percent of the grazed portion of the refuge 
would be in fair to poor condition by the year 2000 as opposed to the 
present figure of about 8 percent. Continued over-grazing of those 
allotments in deteriorated condition could compound the situation for 
the entire allotment, as livestock are forced to range farther from 
preferred range to find forage. Those allotments constitute a minority 
on a refuge-wide basis, however, and the overall range trend would 
continue to be slightly upward. Range objectives would not be met under 
this alternative. 


67 


Consequences 
No Action 


The slow upward trend for the refuge as a whole would mean that 
additional AUMs would be available for livestock or wildlife use (min- 
imum of 1,000 AUMs by the year 2000). 

Forage allocations to livestock would continue to depress habitat 
values for wildlife. Habitat values for wildlife would stay at or near 
present levels. There would be continued heavy use of range areas by 
livestock near water and on level to moderately sloping terrain. Use of 
primary wildlife areas by livestock would be heavier than desirable in 
some locations near dependable water. Lack of water in other areas 
would minimize all livestock use. The interspers ion effect thus created 
would have beneficial impacts on some species of wildlife. Birds of 
open areas, such as prairie horned larks, lark buntings, and several 
species of shorebirds, would benefit from livestock grazing effects. 
Prairie dogs and animals closely associated with prairie dog towns would 
benefit because localized disturbances such as overgrazing, which origi- 
nally allowed establishment of the towns, would continue. 

Seasons of use would continue to detract from overall range improve- 
ment potential. Several allotments have year-long grazing or early 
spring use authorized on a recurring basis. This type of grazing is not 
conducive to range improvement because the same localized areas are con- 
tinuously subjected to heavy use with deterioration of plant and soil 
resources resulting. 

No new range developments which would significantly affect wildlife 
and wildlife habitat are proposed under this alternative. However, 
maintenance of some existing range facilities would have adverse impacts 
on wildlife habitat. Several improvements such as ponds in hardwood 
draws or breaks are presently located in primary wildlife habitat. 
Continued maintenance of these sites in important wildlife areas might 
increase opportunities for game-livestock competition. Mackie (1970) 
felt that control of water associated with primary cattle range could 
serve as a tool to provide better livestock distribution and lessen 
opportunities for game- live stock competition. He recommended no water 
developments on terminal portions of larger ridges or on smaller ridges 
where the area available for livestock is limited. This would lower the 
likelihood of game-livestock competition on important wildlife range. 

The retention of private cabin sites and developed recreation areas 
would continue to exclude a limited amount of land from use as wildlife 
habitat and result in attendant loss of wildlife populations that would 
otherwise be associated with such habitat. 

RECREATION AND CULTURAL RESOURCES 

Generally, this alternative would contribute the least toward 
meeting national and regional recreation requirements and needs iden- 
tified in the Nationwide Outdoor Recreation Plan (Bureau of Outdoor 
Recreation 1973) and Montana Statewide Outdoor Recreation Plan (Montana 
Department of Fish and Game 1978). It also would accomplish little in 
terms of meeting recreation objectives established for CMR. 

Present forage allocations would provide for undesirable aesthetic 
qualities in several allotments which have a considerable portion of 
deteriorated range. Most of these allotments are found in the Big Dry 


68 


Arm which receives a considerable amount of recreational use during the 
grazing season when poor range conditions are most obvious. 

Maintenance of the No Action alternative would provide ample view- 
ing opportunities of prairie dogs and other species associated with poor 
or fair range conditions. Some increases in visitation are anticipated 
from minor improvements in interpretive facilities. 

Since there would be only limited development or expansion of 
existing recreation areas, concentrated public use would continue in the 
vicinity of major recreation areas, especially at COE sites near Fort 
Peck and along the Big Dry Arm segment of the reservoir and between Fred 
Robinson Bridge and Seven Mile Creek on the west. 

Impacts of public use on lands adjacent to the refuge would be 
similar to those on the refuge where comparable conditions and facil- 
ities occur. Most roads would remain unusable in bad weather, and non- 
wildlife-oriented uses would predominate. 

Reservoir water level fluctuations would continue to periodically 
inundate the headwaters area, causing alterations to wildlife habitat 
and associated wildlife-related recreation opportunities. Some historic 
buildings and archeological/paleontological sites would be lost or 
remain unidentified. A few of the more significant sites would likely 
be nominated to the National Register of Historic Places. 

SOCIOECONOMICS 


As mentioned previously, there are presently 60,108 federal AUMs 
permitted on the refuge; 3,584 of these are in a nonuse status. Addi- 
tional AUMs are utilized on state and private lands located within the 
boundaries of the refuge and amount to about 20 percent of the federal 
AUMs permitted by FWS . The number of FWS permitted AUMs would remain 
the same for 1990 and 2005. Because this alternative does not affect 
the number of future AUMs on the refuge, no direct or indirect economic 
effects would occur due to grazing. This alternative would provide 
little or no impacts to operators who graze livestock on CMR. It would 
provide for continuance of the lifestyles to which they are accustomed 
and would result In minimal new governmental interference with their 
operations . 

In 1978, recreation visitor days totaled 357,000 (Table 12). 

Changes attributable to this alternative would be the difference between 
the 1978 figures and the estimate for 1990 and 2005. The direct econo- 
mic effects are estimated to be $132,100 between 1978-90 and $112,200 
between 1991-2005. Present value of these direct effects is $677,800. 
The figures are not adjusted for any anticipated price level changes. 

Indirect economic effects of an additional 21 man-years of employ- 
ment and $153,900 in income would result from an increase in visitation 
during 1978-85. Likewise, an additional 15.5 man-years and $117,700 in 
income would result from an increase in visitation between 1986 and 
2000 . 

Table 12 summarizes the noneconomic effects which would result from 
implementation of the No Action alternative. A detailed economics 
methodology is presented in Appendix 13. 


69 


Consequences 
No Action 


Table 12. Noneconomic effects, No Action alternative, Charles M. 
Russell National Wildlife Refuge, Montana. 



Present 

situation 

(1978) 

No 

1990 

Action 

2005 

Habitat quality^ - 

Sharp-tailed grouse 

4.6 

4.6 

4.7 

Mule deer 

5.6 

5.6 

5.8 

Pronghorns 

5.2 

5.2 

5.3 

White-tailed deer 

5.4 

5.4 

5.6 

Elk 

6.0 

6.0 

6.2 

Waterfowl 

3.4 

3.4 

3.4 

Development 

Burn (acres) 

0 

0 

0 

Plant trees (acres) 

0 

0 

0 

Plant shrubs (acres) 

0 

0 

0 

Soil ripping (acres) 

0 

0 

0 

Ponds (acres) 

0 

0 

0 

Fences (miles) 

Exclosure 

0 

0 

0 

Boundary (aprx.) 

50 

56 

56 

Interior 

Unknown 

0 

0 

Water projects (No.) 

Ponds (aprx.) 

150 

150 

150 

Troughs 

13 

13 

13 

Springs 

0 

0 

0 

Visitor days 

FWS 

64,000 

67,000 

68,000 

Other 

293,000 

326,000 

356,000 

Total 

357,000 

393,000 

424,000 

Forage (AUMs) 

Wildlife 3 

50,000 

50,000 

51,000 

Livestock (active) 

56,524 

56,524 

56,524 

Total 

106,524 

106,524 

107,524 

Range condition (%) 

Poor 

1 

1 

1 

Fair 

7 

8 

10 

Good 

74 

72 

69 

Excel lent 

18 

19 

20 


0-2.5 = poor, 2. 6-5.0 = fair, 5. 1-7. 5 = good and 7.6-10.0 = excellent. 
A precise estimate of acres enclosed/mile of fence is not provided 
due to presently undetermined topography and shape of exclosure. 

A general rule of thumb is 40 acres enclosed per mile of fence. 

These figures represent active AUMs; 3584 AUMs are inactive; thus 
the total is 60,108 AUMs. 


70 


ALTERNATIVE B 


(Proposed Action) 


SOILS -WATERSHED 


Fire management practices would result in the opening of some 
coniferous forest stands to increase grass, forb, and shrub levels to 
retard runoff and soil loss. Eichhorn and Watts (1974) observed that 
the evergreen litter and tree overstory of unburned sites are less 
effective in reducing erosion than nontree vegetation on burned sites. 
Grazing reductions, planting, and exclosures would provide more residual 
cover and shrub communities which would also retard runoff and decrease 
eros ion. 

Areas on level to moderate slopes and within one mile of water 
would generally receive light to moderate use by livestock because of 
reduced stocking levels. More fragile areas such as shale, breaks and 
badlands range sites, and steep terrain with over 20 percent slope 
gradient would receive little or no livestock grazing. Any use on these 
areas would tend to increase soil or parent material loss because of 
vegetation cover removal and livestock movements (W. Larsen personal 
communication). Soil erosion on these fragile areas would be reduced 
and essentially confined to geologic processes. Increased litter cover 
on areas considered to be principal livestock range would be expected. 

Bare soils on the most productive range sites, such as clayey, 
silty, sandy, and overflow, would be lowered from the present average 
range of 20-42 percent to 15-25 percent by 1990. This would lower 
present rates of erosion by allowing increased water infiltration into 
the soil and reducing amounts of soil exposed to the elements. Overland 
runoff and sedimentation would be lowered, and water quality would be 
enhanced . 

Boundary and interior fences would help improve soils and watershed 
conditions within several allotments through control of livestock. This 
would help improve range conditions and ultimately soils and watershed 
values through increased plant and litter cover. This would benefit 
wildlife habitat. No significant detrimental impacts are expected to 
occur to wildlife as a result of fence construction. 

A water facility proposed for the Kill Woman allotment and approved 
for construction by the Soil Conservation Service, would help eliminate 
a head -cut ting problem in one drainage through control of runoff. Other 
water facilities planned would result in only minor enhancement of soils 
and watershed conditions. 

WILDLIFE HABITAT-RANGE RESOURCES 


Reintroduction of black-footed ferrets and peregrine falcons would 
provide additional wildlife diversity on CMR and help perpetuate these 
two species. Re introduction of black-footed ferrets would involve main- 
tenance of prairie dog towns. These areas would remain in poor range 
condition, but would provide desirable wildlife habitat for several 


71 


Consequences 
Proposed Action 


wildlife species. Prairie dog expansion onto adjacent landowners' lands 
might necessitate control measures. Other management decisions concern- 
ing prairie dog control would be made upon completion of the present 
prairie dog study on CMR. 

Lack of residual vegetation for cover and food is limiting to 
several species of wildlife. Reducing grazing 33 percent would increase 
residual vegetation to provide nesting and hiding cover and forage. 

Reduction or elimination of livestock AUMs would occur where com- 
petition between bighorn sheep and livestock occur. There would be 
increased residual cover which would provide more forage for bighorn 
sheep. Eichhorn and Watts (1976) assessed livestock-bighorn sheep 
competition in the Two Calf drainage, indicating that limited winter 
habitat and competition with livestock have limited the success of the 
sheep reintroductions there. Bighorn sheep would increase in number as 
a result of reduced competition with livestock. 

It is expected that 70 percent of potentially suitable sites would 
have 8-10 inches of residual cover by 1990. This would provide sharp- 
tailed grouse with the cover they require for nesting (Christensen 1971, 
Sisson 1976) and ^ould increase spring bird population^ from approxi- 
mately 5 birds/mi to a projected level of 30 birds/mi on suitable 
habitat (Fish and Wildlife Service 1978). This would also provide 
improved shelter and protection from predation for all ground nesting 
birds, improved night roosting areas for sharp-tailed grouse, improved 
insect food sources for bluebirds, more cover for small rodents and 
porcupines, and a greater forage supply for mule deer, elk, and prong- 
horns . 

Approximately 30 percent of the suitable areas would not attain 
this level of cover by the year 2005, because areas on level to moderate 
slopes and within one mile of water would receive light to moderate use 
by livestock. These areas would have less cover and thereby benefit 
species such as mountain plovers, burrowing owls, ferruginous hawks, 
prairie horned larks, and prairie dogs (Bureau of Land Management 1979). 

Changes from sheep to cattle and changes in grazing intensities and 
seasons of use would increase forbs for pronghorns and mule deer by 30- 
35 percent. According to Mackie (1970), forbs constitute an important 
component in the summer and fall diet of mule deer in the Missouri River 
breaks. Cole (1956) made similar statements for pronghorns. 

The response of small mammals to increased amounts of cover and 
available forage would be varied. Voles, which rely heavily on grass 
for food and cover, would increase while deer mice, which use plant 
seeds to a greater extent for food and are better adapted to sparsely 
vegetated areas, would probably decrease (Black 1968, R. Moore personal 
communication) . 

Prescription grazing would maintain stands of big and silver sage 
at present levels; different intensities of livestock use would modify 
plant composition to favor sagebrush (heavy use in early spring) or 
grasses and forbs (light or no use). This would provide enhanced fawn- 
ing areas and winter cover for resident pronghorns (Bayless 1969) . 
Different treatments would change habitat conditions to meet particular 
wildlife needs in terms of food or cover at critical periods of the 


72 


year. Large numbers of pronghorns move into the breaks and CMR during 
severe winters. When these conditions occur, pronghorns need the best 
possible habitat conditions to survive. Improved habitat conditions 
under the Proposed Action would enhance survival of the herds using the 
refuge at these critical periods. 

Prodgers (1979) stated: 

"Shrub dominated communities afford some of the best 
wildlife habitat on the CMR NWR by providing food, cover, 
and perches. With a few exceptions (such as rabbitbrush, 
sagebrush, and greasewood) , shrubs are found on sites 
with above average moisture and low or normal soil salt 
levels . . . 

"Shrubs were much more abundant on the Refuge prior to 
the great drought of the 1930's. Murie (1937) observed 
that as much as 95 percent of the buffaloberry was dead in 1935, 
and severe drought lasted several years after that. When 
attempting to establish more shrubs on the Refuge, the 
Manager should recognize that success will be nil in drought 
years, though shrubs established in prior years may persist, 
perhaps as a function of length of establishment... 

"If shrubs are established on suitable sites, they 
can be expected to reproduce naturally within several 
years and thus colonize suitable adjacent areas. How- 
ever, most shrubs are palatable to livestock and grazing 
could endanger not only reproduction, but survival itself. 

Seeded or planted areas should be protected from grazing 
until desired shrub abundance is achieved, and thereafter, 
the effects of grazing should be carefully monitored..." 

Prescribed burning on approximately 7,700 acres, planting of suit- 
able shrubs on approximately 500 acres, and construction of livestock 
exclosures in key hardwood draws would improve the all-important shrub 
communities by the year 2005. This would provide an increased food base 
for deer and upland game birds as well as cover for deer, sharp-tailed 
grouse, and several small birds and mammals. 

Seventy percent of the suitable hardwood draws would have the 
desired shrubs by the year 2005. Because shrub responses are slower 
than the effects of reduced grazing upon herbaceous cover levels, con- 
tinual improvement in shrub quality would occur for another 40-50 years. 

Eichhorn and Watts (1974) found that burned areas in the Missouri 
breaks produced substantially more forbs and shrubs than unburned 
control sites. Those shrubs which could be enhanced on the refuge 
by proper fire management include rose, chokecherry , snowberry , buffaloberry, 
serviceberry , and skunkbrush sumac (Fish and Wildlife Service 1978). Mule 
deer, sharp-tailed grouse, pronghorns, and white-tailed deer would all 
benefit from an increased food base. There would also be summer cover 
for mule deer, sharp-tailed grouse, song birds, porcupines, bobcats, 
and elk. Winter roosting areas for sharp-tailed grouse would be en- 
hanced as would nesting sites for passerines and winter use areas for 


73 


Consequences 
Proposed Action 


mule deer and bobcats. Habitat quality for sharp-tailed grouse would 
increase from fair to good (56 percent increase in habitat quality) by 
the year 2005, and mule deer habitat in hardwood draws would increase in 
quality by 28 percent for the same period (Appendix 14). 

The few riparian zones proposed to be fenced would improve sub- 
stantially. Unfenced riparian zones would receive lighter overall 
grazing use and re-establish riparian habitat more gradually than the 
fenced areas. Good habitat would be achieved by the year 2005 on these 
unfenced riparian areas, which include Slippery Ann Creek, Rock Creek 
(west), Timber Creek (east), and Fourchette, Big Dry, Squaw, and Hell 
creeks. Although riparian areas and ponds would continue to sustain a 
disproportionate share of livestock grazing, reductions in AUMs under 
this option would substantially reduce pressures on areas that are over- 
utilized. To restore and maintain vegetative quality and vigor to all 
important riparian areas and ponds, livestock grazing would have to be 
eliminated in the entire allotment or the areas completely fenced 
(Hormay 1976). Most of the upland ponds would still have limited value 
as waterfowl production areas. 

Bottoms along the Missouri and Musselshell rivers would continue 
to remain fenced and unavailable to livestock except on a prescription 
basis. This would preserve the riparian community and maintain the 
overall wildlife habitat for white-tailed deer in good condition by 
the year 2005. 

Phasing out of the cooperative farming program would allow the 
bottoms along the Missouri River to revert to a natural riparian com- 
munity, benefiting some wildlife species but adversely impacting others. 
Mule deer habitat in the big sage-gr easewood -grassland , ponderosa pine- 
juniper, and grassland»deciduous shrub types would be improved 34 per- 
cent by the year 2005 as a result of increased forb and shrub levels 
(Appendix 14). This would mean increasing the habitat's ability to 
support an over-wintering population of from 6-10 deer/mi (Fish and 
Wildlife Service 1978). Elk populations would not change significantly 
as a result of the Proposed Action. Elk use large areas off the refuge 
which contain essential habitat components beyond CMR's control. 

Overall habitat quality would increase 16-105 percent depending on 
wildlife species evaluated (Appendix 14). Wildlife objectives would be 
met. The reduction in grazing to accomplish this increase in habitat 
quality might result in lowering of habitat quality on private lands if 
landowners increase stocking rates on these lands to compensate for the 
loss of AUMs on the refuge. 

Increasing vegetation along continuous and intermittent streams 
would reduce siltation and stabilize stream flows which could benefit 
the reservoir fishery. 

Impacts from predator and animal control would be the same as the 
No Action alternative. 

Range communities would improve from the proposed forage alloca- 
tions. Approximately 25 percent of the grazed portions of the refuge 
would be in excellent condition by 1990, and 35 percent in excellent 
condition by the year 2005. Fair condition range would be reduced from 
the present level of 7 percent to an estimated 3 or 4 percent because of 
reductions in livestock on overgrazed allotments, particularly in the 


74 


Big Dry Arm area. Grazed portions of the refuge in poor ecological 
condition (about 1.1 percent) would not change appreciably. These areas 
are most commonly associated with prairie dog towns or are flood plains 
which are periodically disturbed by floods or ice jams. Owensby et al. 
(1973) found that little change occurs on poor condition range after 10 
years. They estimated it would take 40 years for overgrazed range to 
attain excellent condition under complete rest in a precipitation zone 
of 25 inches annually. It is therefore unlikely that the poor condition 
range on the refuge would be significantly enhanced by the year 2005. 

Although overutilized areas would be reduced under this alter- 
native, some of these sites would be present as long as cattle are 
grazed on a seasonal or year-long basis. Areas with no livestock 
grazing, or those having rotation systems or prescription grazing would 
not have significant distribution problems because of a periodic rest 
cycle or total rest to facilitate vegetal response. 

The proposed livestock reductions would help limit most livestock 
grazing to areas with a slope gradient of less than 20 percent and 
within one mile of water. Mackie (1970) observed that 90 percent of 
livestock use in the Missouri breaks was within one mile of water, and 
over 80 percent occurred on slopes of less than 10 degrees gradient. 
Allocations of forage to livestock were made taking these factors and 
soils limitations into consideration to eliminate range overuse by 
livestock on primary ranges (Appendix 15) . This would provide a greater 
amount of forage per animal on these primary livestock ranges and reduce 
the need for them to range further for forage. 

Light stocking levels proposed by this action would have the effect 
of maintaining productivity and a diversity of habitat conditions. Van 
Poollen and Lacey (1979) reviewed pertinent literature with respect to 
grazing systems and intensities on western ranges: 

"Mean annual herbage production increased by 13 percent 
when grazing systems were implemented at moderate stock- 
ing intensities. Increases were greater (35 and 27 per- 
cent) when continuous livestock use was reduced from 
heavy to moderate and moderate to light, respectively. 

This indicates that adjustments in livestock numbers 
have a greater effect on herbage production than do 
grazing systems." 

Grazing systems evaluated and compared with continuous use included 
rotation, deferred, rest rotation, and deferred rotation systems under 
moderate stocking levels (40-60 percent utilization of forage). 

Klipple and Costello (1960) in a 13-year study provided an appro- 
priate description of the effects of light grazing by livestock on 
vegetation. 

"Light grazing, as defined in this study, was charac- 
terized by distinct patches of grazed vegetation surrounded 
by areas of almost ungrazed vegetation. Grazed areas had 
as much as 50 percent of the current growth removed. Un- 
grazed plants of the highly palatable species were easily 
found, and conspicuous stubble remained on the grazed plants. 

Plants of low palatability , such as three-awns, broom snake- 
weed, rubber rabbitbrush, and slender bush eriogonum, seldom 
showed grazing use." 


75 


Consequences 
Proposed Action 


This type of grazing by domestic livestock would provide the diver- 
sity of habitat conditions needed to achieve desired wildlife popula- 
tions and diversity of species. Range objectives would be achieved with 
this alternative. 

Klipple and Costello's description of the effects of light grazing 
coincides with a description of the effects of bison grazing on the 
National Bison Range, Montana (R. Brown personal communication). Based 
on this, forage allocation under this alternative could approximate 
grazing by bison. 

Little or no livestock grazing would occur on sites more distant 
from water or on steeper terrain. Hardwood shrubs on these more remote 
areas would be able to complete their growth cycle without being affected 
by livestock trampling and grazing. Resultant livestock-wildlife 
stocking levels would tend to be somewhat in line with Mackie's (1970) 
management considerations for a joint use range situation, where live- 
stock are favored on the more level ranges close to water, and wildlife 
are favored on steeper, more inaccessible terrain having good security 
cover or in areas more remote from water. 

In some portions of the refuge, a scattered pattern of landownership 
exists between federal, state, and private land. The management of CMR 
will be coordinated and integrated, where feasible, with the objectives 
of other federal agencies, state agencies, and private landowners on and 
around CMR. 

The Proposed Action alternative would tend to produce a diversity 
of habitat conditions. The desired vegetative components of residual 
cover and enhanced shrub production would be produced on a larger 
percentage of potentially suitable sites, but use patterns by livestock 
would ensure maintenance of habitat conditions for wildlife species 
having less stringent residual cover and shrub requirements. The result 
of grazing used as a management tool would be to maintain or alter 
habitat to benefit a particular wildlife species. Grazing at the pro- 
posed levels would maintain vegetative productivity and vigor, but would 
also provide for the necessary residual cover to meet requirements of 
ground nesting birds and small mammal species. Forage equivalent to 
approximately 69,000 AUMs would be made available for wildlife for 
consumption as food or for cover requirements by 1990. The refuge would 
be managed under the philosophy that light livestock grazing levels are 
not detrimental to wildlife populations (Appendix 16). 

Lower grazing pressure by livestock would provide enhancement of 
vegetative resources in some deteriorated areas. An increase of about 
5,000 AUMs of forage should be realized by the year 2005 from the im- 
proved range conditions and would be available to wildlife. 

Mackie (1970) felt that the onset of livestock grazing in the 
Missouri breaks should be delayed until mid -May when plant growth is 
more advanced. Smith (1979) supported Mackie's discussion in regard to 
plant responses to grazing and range readiness. Some disturbance with 
wildlife nesting and fawning activities could be expected by allowing 
onset of livestock grazing in mid-May. Under the light livestock use 
proposed by this alternative, these disturbances are not expected to be 
significant. If conflicts do occur, adjustments in grazing seasons will 


76 


be made as required to minimize conflicts with wildlife. Fall and 
winter livestock use on range grazed by elk and deer also increases 
livestock-wildlife competition for forage. Such use has been identified 
as a problem in several allotments. Implementing later turn-in and 
earlier turn-out dates for livestock would mean a better opportunity to 
enhance habitat conditions for wildlife by allowing a higher state of 
range readiness in the spring before onset of livestock grazing and less 
competition for forage between livestock and wildlife on winter ranges. 

Reduced grazing levels may have the tendency to open sagebrush 
stands and reduce canopy cover of sagebrush because grasses in the stand 
would receive less grazing pressure. Grasses have root systems better 
adapted to catching infiltrating water, and under normal livestock 
grazing pressures, grasses are selectively taken in preference to the 
relatively unpalatable sage. On portions of the refuge, heavy seasonal 
grazing would eventually result in changes in plant species composition 
favoring sagebrush. Under the Proposed Action, prescription grazing 
would be utilized to help maintain sagebrush communities if they begin 
to decline to benefit such species as mule deer, pronghorns, and sage 
grouse . 

Several existing reservoirs would be enlarged and rehabilitated. 
This would enhance conditions for shorebirds and waterfowl. Some new 
fences would be constructed along the refuge boundary to control live- 
stock and help attain desired vegetative cover levels. Some minor 
riparian areas across the refuge lack good shrub communities; construc- 
tion of a minimum of six miles of fence would help alleviate this situ- 
ation. Habitat quality would be expected to increase from fair to good 
as a result of this and other proposed treatments. 

New recreation areas and related developments would be prohibited 
near sensitive wildlife habitat, and incompatible activities would be 
curtailed during critical nesting and breeding seasons. Most recrea- 
tional development would occur at areas already disturbed by facilities. 

RECREATION AND CULTURAL RESOURCES 


Compared to the others, this alternative would contribute an 
intermediate amount toward meeting national and regional recreation 
requirements and needs identified in the Nationwide Outdoor Recreation 
Plan (Bureau of Outdoor Recreation 1973) and Montana Statewide Compre- 
hensive Outdoor Recreation Plan (Montana Department of Fish and Game 
1978). Recreation objectives identified for CMR would be satisfied. 

Introduction of endangered or unique species such as peregrine 
falcons, black-footed ferrets, swift fox, and bighorn sheep would in- 
crease the diversity of animals available for wildlife-oriented recre- 
ation. The rare occurrence of these species, and the equally rare 
opportunities to view them anywhere else, would provide a once-in-a- 
lifetime opportunity for many visitors. Introduction of peregrine 
falcons would necessitate restriction of human disturbance during the 
breeding season (Snow 1972). 

Improvement of habitat would increase the numbers of wildlife that 
would be observed or taken. Any stabilization of water levels in Fort 
Peck Reservoir that may be possible would enhance recreation, wildlife. 


77 


Consequences 
Proposed Action 


and fishery values and retain the approximate 21-mile reach of the 
Missouri River from the Fred Robinson Bridge to headwaters of Fort Peck 
Reservoir in a free-flowing condition. This would be accomplished, as 
conditions permit, without major impacts on flood control, hydropower 
generation, water supply, recreation, or fish and wildlife. 

In addition to the cultural surveys that would be undertaken, other 
benefits would accrue due to the provision of a historic tour route and 
interpretation of numerous historical, archeological, and paleontologi- 
cal features throughout the refuge. Sites eligible for inclusion on the 
National Register of Historic Places would be identified, and areas 
having significant values would be designated as special districts or 
natural landmarks. 

The proposed forage allocations would provide enhanced range con- 
ditions on a refuge-wide basis. This would enhance the aesthetic 
quality of the refuge and provide a higher quality recreational ex- 
perience as well as a greater opportunity to recreate. Prescribed 
burning would result in a lowering of visual quality for 1-5 years. 

The water pipeline and troughs that would be constructed about one 
mile from the present wildlife tour route on the west end of the refuge 
would help attract livestock concentrations away from the area and 
improve wildlife viewing potentials. 

Increases in visitation would occur due to provision of various 
interpretive facilities, including visitor contact stations, a sail- 
powerboat tour route, backcountry-nature trails, and interpretive pro- 
grams and displays. These uses would enable the public to acquire a 
better understanding of and appreciation for wildlife and related re- 
sources. The only new area to be developed would be at Fourchette Bay 
which would provide access and facilities for recreationists on the 
northwest end of the refuge. About half the additional use associated 
with this site is expected to be wildlife and wildlands-oriented . There 
would be a small increase in vehicular travel over roads leading into 
the refuge across BLM land and some additional use of BLM lands for 
recreation. Improving roads would provide better access for fishermen, 
hunters, and other recreationists. 

Establishing scattered access sites to the reservoir over a large 
area would more evenly distribute use, reducing congestion at some 
existing sites and improving the quality of the recreation experience. 

Development and use of roads and permanent recreation facilities 
would reduce available wildlife habitat. Perry and Overly (1977) found 
that vehicular use of all rhads in the Blue Mountains of Washington 
(main, secondary, and primitive) had a significant detrimental effect on 
use by big game to a distance of one-half mile as compared to control 
plots where no roads were located. Proper planning of road systems on 
the refuge would serve to minimize potentially detrimental impacts to 
wildlife . 

Proper planning of public use resulting from a management study of 
the Slippery Ann area would ensure a high quality recreation experience 
while minimizing management problems and impacts on wildlife. By per- 
mitting landing of aircraft only at specified locations on the refuge, 
there would be no significant conflicts with wildlife or recreationists. 


78 


SOCIOECONOMICS 


Grazing would be reduced from 60,108 to 40,482 AUMs by 1990. This 
represents a decrease of 19,625 AUMs or about 33 percent. Between 19 90- 
2005, grazing activities would be increased slightly from 40,482 to 
40,628 AUMs. This increase would result from proposed land acquisition 
on CMR. The self-furnished AUMs on these lands would be converted to 
federal AUMs as the tracts are acquired. The direct effect of the AUM 
reductions from 1978-90 is estimated at a negative $347,000 in sales. 
This direct effect would be sustained almost entirely by permittees who 
use the refuge. The possible consequences of implementing the Proposed 
Action upon individual permittees who graze livestock on the refuge are 
shown in Appendix 10. 

As Appendix 10 discusses, while the average impact under the Pro- 
posed Action to the ranchers would be about 3 percent, eleven ranchers, 
who have substantially higher than average dependency, will be impacted 
more severely. 

Table 13 shows the project levels of annual visitation for years 
19 90-200 5. Direct and indirect annual economic effects in terms of 
sales are +$162,911 for 1985 and +$488,520 for year 2005. This trans- 
lates into a gain of 4 workers per year in the 1978-90 period, and an 
additional 11 workers per year in the 1991-2005 period. 

The net direct plus indirect effects (combination of grazing losses 
and recreation gains) of the Proposed Action is a loss of $763,579 in 
sales and 9 workers annually in the 1978-90 period. The loss in sales 
is $451,320 and employment is 2 workers annually in the years 1991-2005. 
Both result in a change in employment of less than 1 percent. 

Table 13 summarizes the non-economic effects which would result 
from implementation of the Proposed Action. 

There are about 800 acres of cropland on the refuge used primarily 
for hay production. Assuming a hay price of $50 per ton and a 1 ton per 
acre yield, gross revenue would total $40,000 per year. With production 
costs at $30 per ton, net revenue would be about $16,000 per year. If 
the loss of this feed required importation of an equal amount of live- 
stock feed, the cost per ton would be about $16 more than local prices, 
thus, creating an added cost to producers of about $12,800 per year. 


79 


Consequences 
Proposed Action 


Table 13. Noneconomic effects. Proposed Action alternative, Charles M. 
Russell National Wildlife Refuge, Montana. 



Present 

situation 

(1978) 

Proposed 

1990 

Action 

2005 

Habitat quality^ 

Sharp-tailed grouse 

4.6 

5.8 

7.2 

Mule deer 

5.6 

6.8 

7.2 

Pronghorns 

5.2 

6.5 

7.4 

White-tailed deer 

5.4 

6.5 

7.4 

Elk 

6.0 

7.0 

7.6 

Waterfowl 

3.4 

4.2 

7.0 

Development 

Burn (acres) 

0 

1900 

7700 

Plant trees (acres) 

0 

0 

0 

Plant shrubs (acres) 

0 

100 

500 

Soil ripping (acres) 

0 

0 

0 

Ponds (acres) 

0 

3 

3 

Fences (miles) 

Exclosure 

0 

2 

6 

Boundary (aprx.) 

50 

91 

97 

Interior 

Unknown 

21 

21 

Water projects (No.) 

Ponds (aprx.) 

150 

153 

153 

Troughs 

13 

23 

23 

Springs 

0 

0 

0 

Visitor days 

FWS 

64,000 

70,000 

73,000 

Other 

293,000 

326,000 

360,000 

Total 

357,000 

396,000 

433,000 

Forage (AUMs) 

Wildlife 

50,000 

69,000 

74,000 

Livestock (active) 

56,524 J 

40,482 

40,628 

Total 

106,524 

109,482 

114,628 

Range condition (%) 

Poor 

1 

1 

1 

Fair 

7 

7 

4 

Good 

74 

67 

60 

Excel lent 

18 

25 

35 

2 0-2.5 = poor, 2. 6-5.0 

= fair, 5. 1-7.5 = good 

and 7.6-10.0 

= excellent. 

A precise estimate of 

acres enclosed/mile of 

fence is not 

provided 


due to presently undetermined topography and shape of exclosure. A 
general rule of thumb is 40 acres enclosed per mile of fence. 

This figure represents active AUMs; 3584 AUMs are inactive 
totaling 60,108 AUMs. 


80 


ALTERNATIVE C 


(Intensive Wildlife Management) 


SO ILS-WATERSHED 


Fire management practices would result in the opening of some 
coniferous forest stands to increase grass, forb, and shrub levels to 
retard runoff and soil loss. Eichhorn and Watts (1974) observed that 
the evergreen litter and tree overstory of unburned sites are less 
effective in reducing erosion than nontree vegetation on burned sites. 
Planting and exclosures would provide more residual cover and shrub 
communities which would also retard runoff and erosion. 

Forage allocations under this alterative would considerably enhance 
soils and watershed. Livestock grazing would total about 27,000-30,000 
AUMs and would remove considerably less forage compared to present 
levels. This would provide more litter cover on traditional primary 
livestock areas. Water infiltration into the soil would be higher, 
soil compaction and runoff lower, and bare soil exposed to wind erosion 
considerably less. These adverse impacts are cumulative over the years 
and continue from year to year, although they may be lessened by rest 
from grazing. 

Marginal sites that are highly fragile, such as thin breaks, bad- 
lands, and shale would receive little or no use, and soil erosion would 
be minimized. Any use on these areas by livestock tends to increase 
soil or parent material loss because of vegetation cover removal and 
livestock movements (W. Larsen personal communication). 

Approximately 300 miles of boundary fence would control all live- 
stock movements within the refuge and improve range conditions and 
therefore, soils and watershed. 

Ripping of all suitable panspots and dense clay range sites outside 
proposed or designated wilderness areas would improve watershed quality 
and reduce soil erosion through increased plant and litter cover. Ripping 
would allow greater water infiltration into the soil, making it availa- 
ble for plant uptake. This increased water supply would enhance site 
productivity and lower amounts of exposed soil. 

Soil productivity would be considerably enhanced because of reduc- 
tions in rates of soil erosion and soil ripping operations. Increased 
plant and litter cover resulting from improved range conditions and soil 
ripping operations would provide nearly optimal watershed conditions for 
the whole refuge. 

WILDLIFE HABITAT-RANGE RESOURCES 


The general grazing pattern proposed in this alternative would 
probably keep prairie dogs and their associated species at their present 
level (C. Knowles personal communication). Knowles inferred that main- 
tenance and expansion of prairie dog populations is dependent upon man- 
caused disturbances such as livestock grazing, reservoirs, holding 


81 


Consequences 
Intensive Wildlife Mgmt 


corrals, or wells. This is supported by McEneaney and Jensen (1974) and 
BLM (1979), who noted that the presence of prairie dogs is most likely a 
symptom, rather than a cause, of deteriorating range. Prescription 
grazing would be employed as necessary to manipulate habitat for these 
species . 

Since grazing would generally be on a prescription basis, bighorn 
sheep and cattle conflicts would be eliminated. There would be no con- 
flicts between buffalo and bighorn sheep since they would occupy different 
habitat . 

Lack of residual vegetation for cover and food is limiting to 
several species of wildlife. Using prescription grazing as a tool would 
increase residual vegetation to provide nesting and hiding cover and 
forage for wildlife. 

The limited livestock grazing allowed would result in an increase 
of residual cover to 8-10 inches on 80-90 percent of the suitable sites 
by 1990. This would provide suitable nesting cover (Christenson 1971, 
Sisson 1976) f^r an optimum number of sharp-tailed grouse in the spring- 
time (30-35/mi ) . It would also benefit a wide range of species de- 
scribed under the Proposed Action alternative. 

Eliminating livestock grazing, except on a prescription basis, 
would provide more forbs for pronghorns and mule deer and increase this 
aspect of habitat quality for both species by 30-45 percent (Appendix 
14). According to Mackie (1970), forbs constitute an important compo- 
nent in the summer and fall diet of mule deer in the Missouri River 
breaks. Cole (1956) reported similar findings for pronghorns. Mackie 
(1970) also reported that forbs comprised an important component in 
diets of cattle during spring, summer, and fall. 

Increased grass and forb production in sagebrush communities would 
be expected under light grazing with a gradual "opening" of the stand as 
the shrubs mature and die. This would be detrimental to wintering popu- 
lations of pronghorns, sage grouse, and mule deer. However, prescription 
grazing by livestock early in the spring (April 15-June 15) would be 
employed for two or three years or longer as required to reverse any 
trend toward grass and forb dominance in a stand. Livestock would 
select the palatable grasses and forbs over sage, thus providing the 
sage with a competitive edge in succeeding years. Some lowering of 
wildlife habitat quality (residual cover levels) may occur in pastures 
subjected to livestock grazing in a given year. 

Wildlife species such as chestnut-collared longspurs, prairie 
horned larks (Owens and Myres 1973), and mountain plovers (Smith 1940), 
which benefit from lower quality residual cover levels, could be detri- 
mentally affected by this action. However, prescription grazing would 
be employed to provide habitat conditions to benefit these species. 

Key shrubs are lacking for use as food as well as cover and perches. 
Prescribed burning on approximately 15,000 acres, planting of suitable 
shrubs on approximately 3000 acres, construction of temporary wildlife 
exclosures in key hardwood draws, and prescription grazing would improve 
important shrub communities. Prescription grazing alone would probably 
not provide for sufficient response by shrubs within the desired time 
frame, especially since shrubs are limited in distribution at present. 

The proposed planting and burning would provide for establishment of 


82 


shrubs on a substantial portion of CMR. Eventual expansion through 
natural reseeding from the planted or burned areas would help meet 
objectives for wildlife in terms of shrub quantity and quality. Ninety 
percent of the potentially suitable hardwood draws would have desired 
shrub densities by the year 2005. Because shrub responses are slower 
than effects of reduced grazing upon residual cover levels, continual 
improvement in shrub quality would occur for another 40-50 years. 

Several other species would benefit from burning and planting. They 
include sharp-tailed grouse (improved roosting cover, Sisson 1976), 
mountain bluebirds (grass and open areas, Baida 1975, Miller 1970), and 
porcupines (improved ground cover, Costello 1966). Prescribed burning 
combined with prescription grazing would improve sharp-tailed grouse and 
mule deer habitat to meet or exceed wildlife habitat objectives for 
these species before the year 2005. 

Most of the river bottoms along the Missouri and Musselshell rivers 
are presently excluded from livestock use. They should be near their 
full potential by 1985. It is estimated that 80 percent of potentially 
suitable areas in these drainages would be at or above desired levels 
for tree and shrub composition by the year 2000. Vegetation around 
stock watering reservoirs should have the 8-10 inches desired residual 
cover on 75-80 percent of suitable areas by the year 2005. This alter- 
native would provide the fastest response for recovery toward climax, 
short of artifically reseeding affected areas and totally resting them. 

T. Planz (personal communication) estimated that waterfowl pro- 
duction at UL Bend alone would be increased from 200 to 2,000 birds with 
intensive management. No figures are available for the entire refuge, 
but it would be expected that similar results could be achieved on a 
limited basis at other areas of the refuge. Some sites would be slower 
to respond because of the present degree of dominance by increaser and 
invader plant species. 

All smaller streams with adequate water sources should have sub- 
stantially improved riparian zones. This would be assisted with tem- 
porary fences to exclude wildlife where necessary. 

More intensive farming in conjunction with improved riparian areas 
would provide optimum food and cover levels for many species of wild- 
life. Mule and white-tailed deer, raccoons, sharp-tailed grouse, ring- 
necked pheasant, turkeys, mourning doves, waterfowl, and most all other 
wildlife species would take advantage of these farm plantings to supple- 
ment their food supply. It is anticipated that elk would be drawn to 
these areas and reduce their use of adjacent private crops. 

Extensive tree planting would provide maximum security cover and 
reduce displacement of elk from human and livestock disturbance. This 
tree planting would be done to improve habitat in Valley County where 
tree cover is presently considered to be inadequate. 

Overall habitat quality could be expected to increase 25-165 per- 
cent over the 20-year period, depending upon the species evaluated 
(Appendix 14). Wildlife objectives would be met. The increase in 
habitat quality and capability to support wildlife which would occur as 
a result of reductions in livestock grazing may result in lowering of 


83 


Consequences 
Intensive Wildlife Mgmt 


habitat quality on adjacent lands if private landowners increase stock- 
ing rates of their lands to compensate for loss of AUMs on the refuge. 

Improving vegetation on continuous and intermittent streams would 
reduce siltation and stabilize stream flows. Establishment of spawning 
habitat on Fort Peck Reservoir could make fish reproduction possible. 

This could reduce the need for stocking operations and increase the 
fishery resource. Impacts from coyote and prairie dog control would be 
the same as the No Action alternative. 

Livestock grazing would be based primarily upon known plant res- 
ponses to grazing levels and seasons of use. Spring-summer use in alter- 
nate years would provide stimulation of vigor and production from 
grazing, with rest periods providing storage of food reserves by plants. 
Grazing in this manner would provide a significant degree of enhancement 
of climax plant species (Smith 1979). Smith (1979) and Hormay (1980) 
indicated that two years of rest following grazing is necessary for 
enhancement of vegetative cover on the refuge. The desired results to 
be achieved in terms of residual cover and habitat quality for wildlife 
would determine the extent of deviation from the prescription grazing 
system described above. For example, several years of moderate to heavy 
grazing might be required to promote habitat conditions for some wild- 
life species. 

Other site specific habitat treatments such as prescribed burning 
would improve those areas for species needing vegetative conditions 
other than climax. In most situations, approximately the same number 
of livestock would be assigned to a given allotment or pasture as are 
presently assigned. However, two years of total rest out of three as 
proposed by Smith (1979) would effectively reduce present annual live- 
stock AUM levels by about two-thirds. Livestock grazing is currently 
conducted at moderate levels on a refuge-wide basis. Employing the 
above concepts refuge-wide would mean an initial reduction in federal 
AUMs to approximately 23,000 by 1990. Grazing on state and private 
inholdings would remain at present levels. By the year 2005, many state 
and private inholdings would be acquired by exchange or purchase and 
converted from self-furnished to federal AUMs. These AUMs would then be 
changed to a prescription basis or retired. By the year 2005, most 
grazing would be on a prescription basis, except of remaining inhold- 
ings. Livestock levels would probably fluctuate between 27,000-30,000 
AUMs. By itself, prescription grazing would not significantly enhance 
habitat quality over grazing levels in the Proposed Action. The pro- 
posed intensive treatments of planting, burning, and ripping would be 
the primary contributing factors involved in improving wildlife habitat. 

Approximately 87,500 AUMs would be allocated to wildlife for food 
and cover requirements by 1990, with about 107,000 AUMs available to 
wildlife by the year 2005. 

This pattern of grazing might eliminate use by small, family-owned 
ranching operations which depend heavily upon AUMs supplied by the 
refuge (Appendix 10). It would mean elimination of most allotments in 
their present form. Some larger operators would continue in a semblance 
of their former status. Livestock operations under this alternative 


84 


would conceivably be run by 15-20 large ranches or corporations which 
are not highly dependent upon federal lands. Individuals, ranching 
operations, or associations having a few to several hundred AUMs would 
possibly be eliminated in favor of large scale operations desiring to 
utilize a minimum of 1,000 or more AUMs during the grazing season. It 
is estimated that approximately 13 operators would be forced out of 
business by this alternative (Appendix 10). Additional economic in- 
formation is not available, and economic consequences could be greater, 
as stated in the Proposed Action alternative. Range objectives would 
not be met under the Intensive Wildlife Management alternative. 

Virtually all the desired areas on the refuge would approach 
excellent range condition by the year 2005. Poor and fair condition 
range would take substantially longer to reach excellent condition. 
Owensby et al. (1973) reported findings from a Kansas study where 
little improvement was noted on deteriorated ranges after ten years 
following fencing. The authors estimated recovery time to excellent 
condition to be 40 years, even with complete rest and in a precipitation 
zone of 25 inches annually. Gradually, however, even this depleted 
range would be restored to its full potential if desired. Wildlife 
objectives might dictate that these areas be maintained at a lower range 
condition. 

All existing grazing systems would be drastically affected by this 
new grazing program. The program would employ a type of grazing which 
would benefit soils, watershed, and wildlife values. 

Prescription grazing would be used as necessary to maintain habi- 
tat conditions at desirable levels to benefit species such as mule deer, 
sage grouse, or black-tailed prairie dogs which have habitat needs of 
other than climax vegetation. Species such as sharp-tailed grouse would 
benefit from the general grazing pattern. 

The graze-rest cycle would provide the optimal situation for shrub 
enhancement. This alternative, together with shrub plantings on 3,000 
acres and prescribed burning on 15,000 acres, would help produce maximum 
shrub enhancement within a minimum period of time. It is estimated that 
90 percent or better of the suitable sites would be in the desired con- 
dition within 50 years, and 75 percent of suitable areas would be at or 
above desired levels for shrubs by the year 2005. Limited grazing and 
proposed shrub management practices would increase the habitat’s ability 
to support an over-wintering population from 6-15 deer/mi . 

Bison would also be introduced into the UL Bend area in suitably 
fenced areas and replace cattle as a principal large grazer. 

Range developments to be implemented include mechanical ripping of 
as much as 38,000 acres of dense clay and panspots range sites. This 
acreage is an estimate of those areas lying outside designated wilder- 
ness, which have potential for treatment because of salt content, low 
water infiltration rates, and sparse vegetation. A two- to five-fold in- 
crease in vegetative biomass is possible by ripping on favorable sites 
(C. Clark personal communication). Wight et al. (1978) reported an 
increase in herbage production of 165 percent, with 10 percent more 
plant-available soil water on panspots sites in southeast Montana fol- 
lowing ripping of the soil surface. J. Rogers (personal communication) 


85 


Consequences 
Intensive Wildlife Mgmt 


stated similar results are normally obtained through breaking the sur- 
face of panspots by ripping or furrowing. These improvements are ex- 
pected to occur on the 38,000 acres proposed for ripping. The perched 
water table often present on these sites would be eliminated; water 
would be allowed to percolate through the soil profile and would help 
flush out accumulated salts; increased quantities of water would be 
available for plant uptake. Greater site productivity would occur as a 
result. Ripping this acreage would increase the carrying capacity of 
the refuge by a minimum of 3,000 AUMs . 

About 200 miles of boundary fence would be constructed. This fence 
would limit livestock access onto the refuge and maintain desired levels 
of livestock to accomplish grazing objectives for habitat improvement. 
Construction of a boundary fence may impede some wildlife movement, but 
this would be partially compensated for by removal of numerous existing 
interior fences. 

New recreation areas and related developments would be prohibited 
near sensitive wildlife habitat, and incompatible activities would be 
curtailed during critical nesting and breeding seasons. Most recrea- 
tional development would occur at areas already disturbed by facilities. 
Eliminating private cabins and establishing wildlife habitat on these 
areas would improve conditions for wildlife on the refuge. 

RECREATION AND CULTURAL RESOURCES 


Compared to the others, this alternative would contribute somewhat 
less than the Proposed Action and No Grazing alternatives toward meeting 
national and regional recreation requirements and needs identified in 
the Nationwide Outdoor Recreation Plan (Bureau of Outdoor Recreation 
1973) and the Montana Statewide Outdoor Recreation Plan (Montana Depart- 
ment of Fish and Game 1978). It would still meet recreation objectives 
identified for CMR. 

Increases in wildlife accompanying this action would provide some 
additional recreation opportunities in the form of viewing, photograph- 
ing, and hunting. The establishment of bison on the refuge would restore 
a sight familiar to the area in the 1800's, and provide the visitor with 
a living reminder of the animals that once flourished here. Introduction 
of peregrine falcons would necessitate restriction of human disturbance 
during the breeding season (Snow 1972). 

Limited conflicts between recreation users and livestock would 
decline as livestock levels are reduced. Livestock damage to culturally 
or historically significant areas would decrease. There would be little 
interference between camper-hunters and livestock on some recreation 
areas. Because bison would be contained in fenced areas, there would be 
no conflicts with recreationists or cultural resources. 

Ripping of dense clay and panspots range sites would have an adverse 
effect on visual resources for a minimum of 3-5 years. Prescribed 
burning would result in a lowering of visual quality for 1-5 years. 

Visitors would be able to view bison, and limited hunting oppor- 
tunities would be possible as the population produced a harvestable 
surplus . 

Due to increased use of refuge roads, there would be corresponding 
increase in vehicular travel over roads leading into the refuge across 


86 


adjoining BLM and private land. Proper planning in terms of a road 
system transportation plan would minimize potentially detrimental 
wildlife impacts. As a result, some additional use of BLM lands for 
recreation would occur. In addition, private land owners would be ex- 
pected to receive increased demand from recreationists seeking to travel 
through their land or hunt. Reductions in livestock grazing levels on 
the refuge would probably result in a less tolerant attitude on the part 
of area ranchers toward any increased recreation use on adjacent private 
lands and a corresponding increase in closure of these lands to public 
use . 

Moderate expansion of existing major recreation areas would create 
a minimum amount of disturbance to the landscape. Eliminating private 
cabin developments and restoring the land to wildlife habitat would 
reduce the number of people recreating on the refuge. The Service and 
the Corps of Engineers will adhere to National Environmental Policy Act 
and P.L. 91-646 in the event any cabin leases are terminated before 
expiration date. Under the provisions of these laws, displaced cabin 
owners are entitled to just compensation for their losses, including 
costs of relocations. The same would apply to high and low density 
recreation areas, which would involve less development than under the 
Proposed Action alternative. 

Except for the degree of recreational development and use antici- 
pated with this alternative, there would be about the same types of 
impacts as envisioned with the Proposed Action alternative. There would 
be some exceptions, however, since only nature trails and no backcountry 
trails would be established. Also, there would be less impact on cul- 
tural resources since damage by livestock would be reduced. 

SOCIOECONOMICS 


This alternative would decrease annual livestock AUMs by 37,285 or 
as much as 67 percent during 1978-1990 period. Such a reduction would 
cause an annual loss of $725,000 in sales to the CMR ranchers, and a 
reduction in hired labor of 2.8 workers. This represents a 6.8 percent 
average reduction in gross income or sales to the ranchers. This alter- 
native would have a larger than average adverse impact to the eleven 
high-dependency ranchers on the CMR. The direct plus indirect effects 
on sales and employment is nearly 2 million dollars and 27 workers. 

While the absolute amounts are large, the regional significance is quite 
small . 

Appendix Table 17a shows the annual visitation by category for the 
years 1990-2005. Direct plus indirect effects of the losses in recrea- 
tion visitation (compared to the No Action alternative) is annual losses 
of $162,911 in sales and 4 workers in the 1978-1990 period, and annual 
losses of $1,086,072 in sales and 24 workers in the 1991-2005 period. 

The net total effect (sum of livestock and recreation direct and 
indirect effects) is an annual 2 million dollar loss in sales and 31 
workers in the 1978-1990 period, and 2.7 million dollars and 48 workers 
in the 1991-2005 period. While in absolute terms the intensive wildlife 
management action has the largest negative impacts, they are still 
regionally insignificant (less than 1 percent change). 


87 


Consequences 
Intensive Wildlife Mgmt 


Table 14. Noneconomic effects, Intensive Wildlife Management alterna- 
tive, Charles M. Russell National Wildlife Refuge, Montana. 



Present 

situation 

(1978) 

Intensive Wildlife 
Management 
1990 2005 

Habitat quality* 

Sharp-tailed grouse 

4.6 

6.8 

8.0 

Mule deer 

5.6 

7.3 

8.0 

Pronghorns 

5.2 

6 . 6 

7.1 

White-tailed deer 

5.4 

7.0 

8.1 

Elk 

6.0 

7.5 

8.0 

Waterfowl 

3.4 

7.0 

9.0 

Development 

Burn (acres) 

0 

3,800 

15,000 

Plant trees (acres) 

0 

6,250 

25,000 

Plant shrubs (acres) 

0 

800 

3000 

Soil ripping (acres) 

0 

0 

38,000 

Ponds (acres) 

0 

225 

900 

Fences (miles) 

Exclosure 

0 

13 

52 

Boundary (aprx.) 

50 

50 

450 

Interior 

Unknown 

0 

0 

Water projects (No.) 

Ponds (aprx.) 

150 

160 

210 

Troughs 

13 

13 

13 

Springs 

0 

0 

0 

Visitor days 

FWS 

64,000 

69,000 

107,000 

Other 

293,000 

321,000 

333,000 

Total 

357,000 

390,000 

404,000 

Forage (AUMs) 

Wildlife 

50,000 

87,500 

107,000 

Livestock (active) 

56,524 J 

22,823 

26,833 

Total 

106,524 

110,323 

133,833 

Range condition (%) 

Poor 

1 

1 

1 

Fair 

7 

7 

4 

Good 

74 

67 

15 

Excel lent 

18 

25 

80 

2 0-2.5 = poor, 2. 6-5.0 

= fair, 5. 1-7.5 = good 

and 7.6-10.0 

= excellent. 

A precise estimate of 

acres enclosed/mile of 

fence is not 

provided 

due to presently undetermined topography and 

shape of exclosure. A 


^ general rule of thumb is 40 acres enclosed per mile of fence. 
These figures represent the active AUMs; 3584 AUMs are inactive 
totaling 60,108 AUMs. 


88 


ALTERNATIVE D 


(Multiple Use) 


SOILS-WATERSHED 

Fire management practices would have the same consequences as the 
No Action alternative. 

Temporary livestock reductions in several allotments plus soil 
ripping practices would provide moderate enhancement of soil produc- 
tivity in treated areas. Areas not receiving these grazing or mechan- 
ical treatments could expect a slight improvement in conditions. Water- 
shed quality enhancement would show similar trends. 

An initial drop of about 4,500 active livestock AUMs below present 
levels would occur in response to a need for enhancing present range 
conditions within several allotments. These decreases would occur 
primarily in the Big Dry Arm portion of the refuge where the most 
serious range condition problems are present. The effect of this tem- 
porary reduction would be to help eliminate an estimated 50 percent of 
the deteriorated range conditions on the refuge. Overland water runoff 
would be substantially lowered on these areas because of increased plant 
and litter cover, with soil erosion lowered as a result. Expected 
increases in litter and plant cover would be somewhere between present 
levels and those expected under the Proposed Action alternative. This 
in turn would place erosional rates for this alternative between the No 
Action and Proposed Action alternatives. Increased plant and litter 
cover would allow cycling of more minerals and nutrients through the 
soil . 

The 38,000 acres proposed for ripping would have higher produc- 
tivity, as previously discussed under other alternatives. Additional 
water developments, fencing, and implementation of new grazing systems 
geared to specific allotment needs should serve to improve soils and 
watershed conditions primarily as a result of increased plant and litter 
cover which will reduce soil erosion and overland runoff. Although some 
proponents of rest-rotation grazing might point out that implementation 
of such systems refuge-wide would improve soils and watershed, an exami- 
nation of available literature does not reveal a clear-cut distinction 
between this and other grazing systems. Gifford and Hawkins (1976) 
evaluated nine separate studies that reflected impacts of various graz- 
ing systems, including rest-rotation, on plant or litter cover. They 
concluded that published evidence failed to show that any one grazing 
system consistently or significantly increases plant and litter cover on 
watersheds. A more realistic situation would require evaluation of 
allotment deficiencies and implementation of grazing systems designed to 
overcome those specific deficiencies. 

Soil resources would be more adversely impacted by this alternative 
than by the Proposed Action due to the significantly greater amount of 
visitation expected to occur. Increased vehicular traffic in the back- 
country areas of the refuge could result in higher rates of erosion and 
rutting of access roads. 


89 


Consequences 
Multiple Use 


WILDLIFE HABITAT-RANGE RESOURCES 

Under this option, prairie dog control would have a short-term 
detrimental effect on the prairie dogs through direct reductions in 
populations. There would be indirect effects on various species de- 
pendent upon dog towns for portions of their life requirements; bur- 
rowing owls would have fewer home sites and raptors and terrestrial 
predators a smaller food base. Potential dens for black-footed ferrets 
would be eliminated. 

Peregrine falcons would benefit as a result of slight increases in 
residual cover to increase suitable habitat for prey species. 

There would be some competition between bighorn sheep and cattle. 
This would be especially detrimental if sheep were confined to a limited 
range also used by cattle, as in fall-winter use allotments where forage 
might be in short supply. 

Lack of residual vegetation for cover and food is limiting to 
several species of wildlife. New grazing systems, seasons of use, 
temporary livestock reductions, and habitat manipulation practices would 
provide a low to moderate amount of improvement in range and wildlife 
habitat quality across CMR. A smaller percentage of the refuge would 
remain in excellent condition as range improvement programs provide 
increased livestock access to formerly inaccessible areas. Areas of 
overuse would improve condition-wise as new improvements allow for 
better livestock distribution. 

An estimated 50 percent of all potentially suitable sites on the 
refuge would have the desired 8-10 inches of residual cover by the year 
2005 as a result of temporary reductions to enhance range condition and 
various treatments proposed under this action. This would provide 
suitable nesting sites for sharp-tailed grouse ^nd provide spring breed- 
ing bird densities of approximately 10 birds/mi and benefit several 
other species as described under the Proposed Action alternative. 

It would help improve overall sharp-tailed grouse habitat from fair to 
good condition. Areas that would not have 8-10 inches of residual cover 
include those key livestock areas within one mile of water on level to 
moderate slopes that are used on an annual, seasonal basis during summer 
months. These areas would have fewer forbs and grasses. 

Residual and emergent vegetation in and around ponds located on the 
refuge would continue to receive heavy use under livestock grazing 
during warm, dry weather. Pond development at UL Bend would cause some 
increase in waterfowl population levels. 

Livestock grazing practices would be expected to result in main- 
tenance or possibly a slight expansion of existing sage communities to 
benefit pronghorns and sage grouse, which, according to Wallstead (1971), 
Eng and Schladweiler (1972), and Bayless (1969), require areas of dense 
big sage (20-30 percent canopy coverage) for use throughout the year. 

An estimated 50 percent of the allotments having habitat shrub potential 
levels of good-excellent would reach these levels by the year 2005. 

Riparian areas grazed on an annual, seasonal or continuous basis 
would continue to receive heavy livestock use, and only fenced areas 


90 


would develop riparian communities of value to wildlife. Limited im- 
provements in shrub communities would be realized on allotments where 
rotation systems of grazing are implemented. 

Key shrubs are lacking for use as food as well as cover and perches. 
Burning to enhance shrubs on 400 acres by 1990, and a total of 1,500 
acres by the year 2000 plus planting shrubs on 300 acres by the year 
2005, would result in slight increases in shrubs. This would provide 
food and cover for mule deer but no significant changes in the habitat's 
ability to support an over-wintering population of mule deer. 

Overall habitat quality would increase 4-120 percent over the 20- 
year period, depending upon species evaluated (Appendix 14). Wildlife 
objectives would not be reached. 

Habitat quality, and therefore capability to support wildlife, 
would be increased only slightly over the present situation for most 
species. This situation, coupled with some increases in livestock 
grazing on the refuge, would mean little or no change in quality of 
habitat on adjacent lands. 

The small improvement in riparian habitat would not significantly 
improve stream flows in continuous and intermittent streams or the 
fishery resource of the reservoir. 

Rough terrain on the refuge limits effectiveness of fixed wing air- 
craft predator control. The use of helicopters would be more efficient 
but is also limited to some degree by topography. Aerial hunting com- 
bined with other types of control would reduce coyote populations on an 
annual basis, but the effects would not be expected to permanently alter 
the coyote population. Impacts from prairie dog control would be the 
same as the No Action alternative. Coyote control for protection of 
other wildlife would have no significant impacts on coyote populations. 
Other small mammal control would have the same impacts as the Intensive 
Wildlife Management alternative. 

Forage allocations would provide enhancement of those allotments in 
deteriorated condition by substantial livestock reductions until im- 
provements occur. Other allotments in good to excellent ecological 
condition would receive few, if any, reductions. Livestock AUMs would 
be increased as range conditions improve; initially approximately 50 
percent of the AUMs in each allotment would be allocated to wildlife. 

Any increases in forage production resulting from improved range con- 
ditions would be allocated to resource values for which the greatest 
need exists (livestock, wildlife, watershed). Range objectives would 
not be achieved with this alternative as wildlife objectives would not 
be realized. 

Approximately 18 allotments would receive increases in use. About 
7,000 AUMs of forage would be available for livestock and 4,500 for 
wildlife on the UL Bend NWR that is presently un- 
grazed. Total federal livestock AUMs would be about 52,000 active by 
1990. Improved range conditions and range improvement programs would 
allow an increase in livestock use to a minimum of 61,260 active federal 
AUMs by the year 2005. This level would be increased as range conditions 
improve or where it is demonstrated that wildlife needs are being met. 
State and private land would be allowed additional AUMs, as conditions 
permit. It is felt that these areas are nearly stocked to capacity at 
present, and any increases in AUMs would be small. 


91 


Consequences 
Multiple Use 


Temporary reductions in livestock use in deteriorated areas would 
help shrub production and establishment. Under seasonal or continuous 
grazing, which would be retained for most allotments, no significant 
increases in shrub production would occur, and trampling of shrubs would 
continue to be a problem. 

Approximately 12 additional allotments under seasonal, continuous, 
or year-long use would be put into a rotation (deferred or rest) system of 
grazing. Fencing and water developments would be constructed in these 
and other allotments as needed. 

Many of the remaining allotments have size, topographic, or other 
constraining factors which would preclude adoption of grazing systems 
which incorporate periods of rest. Under seasonal or continuous use, 
proposed stocking levels would continue to provide some limitation to 
shrub abundance and quality. However, better distribution of livestock 
through range improvement projects and increases in range condition 
would provide a gradual rate of enhancement because of improved forage 
conditions on so-called primary livestock range areas. Improved con- 
ditions on these areas could lower livestock use on more remote and 
rugged areas where competition with wildlife would be more likely. 

Reservoir, spring, and pipeline development would create about 90 
new watering facilities on the refuge by the year 2005. This would 
provide improved livestock distribution and eliminate some deteriorated 
conditions on present concentration areas. However, all water facili- 
ties would still receive a disproportionate amount of use under seasonal 
grazing systems and would not achieve desired wildlife cover levels. 

Under a grazing system where rest intervals are provided, desired cover 
levels would probably be met at least during deferred or rest phases of 
the cycle. Some fencing of reservoirs would occur in pastures used on a 
seasonal basis to improve habitat conditions. 

Other developments such as boundary fences would eliminate ex- 
cessive numbers of livestock which tend to move onto the refuge during 
hot, dry weather. Interior fences would be constructed to implement new 
grazing systems to benefit range conditions, wildlife habitat, and live- 
stock management. No significant detrimental impacts to wildlife are 
expected to occur as a result of fence construction. Ripping of 38,000 
acres would create a minimum 3,000 AUMs of additional forage for wild- 
life and livestock. Additional forage, stocking within authorized 
levels, and better water distribution would reduce grazing pressure on 
those areas which are presently substandard in terms of residual vegeta- 
tion and achieve desired levels of 8-10 inches of cover on 50 percent of 
potentially suitable areas by the year 200 5. 

The season of use for livestock would be provided to meet the 
individual operator’s needs as much as possible, while considering 
growth needs of major forage plant species and critical wildlife values. 

Effects of livestock grazing under various grazing systems have 
been observed to be both beneficial and detrimental to wildlife (Appen- 
dix 16). Stevens (1966) and Mackie (1970) found that elk in Montana 
prefer areas which have had little use by cattle and that their move- 
ments are influenced by presence of cattle. Skovlin et al. (1968) found 
that elk use in the Blue Mountains of Oregon was significantly less on 


92 


range cohabited with cattle than in areas where cattle use was restrict- 
ed. Rates of elk use decreased as cattle stocking increased, but moderate 
cattle stocking inhibited elk as much as heavy cattle stocking. Skovlin 
and Harris (1970) found that elk preferred season-long cattle ranges to 
deferred rotation ranges when cattle stocking was light. However, elk 
preferred heavily stocked deferred rotation ranges to heavily stocked 
season-long ranges. Knowles (1975) found that elk tended to concentrate 
in areas not grazed by cattle on the Nichols Coulee allotment of CMR. 
Wittinger (1978) reported similar findings in the Salmon River drainage 
of Idaho. This distribution pattern suggests that land use competition 
occurs between elk and cattle. Knowles (1975) also suggested that 
limited mobility of mule deer made them vulnerable to any situation 
which resulted in intensive use of their home range by other ungulates. 
Intensive livestock grazing could therefore have detrimental impacts 
upon mule deer populations. 

In looking at impacts of rest-rotation upon smaller forms of wild- 
life, Gjersing (1975) indicated that both breeding pairs of ducks and 
broods increased in response to periodic relief (rest-rotation) from 
grazing. This alternative would be expected to significantly affect 
wild ungulates by increasing opportunities for competition for forage. 
Social intolerance would be an important factor which would lower hab- 
itat quality for mule deer and elk. Sharp-tailed grouse would be ad- 
versely affected by lower residual cover levels in some areas. Some 
benefits to mule deer and sage grouse could be expected in terms of 
improved sagebrush communities for winter forage. Livestock feeding 
patterns would tend to maintain or expand existing communities. Prairie 
dogs and their associated species are expected to benefit from the Multi- 
ple Use alternative which would maintain heavy livestock use areas in a 
disturbed condition. The net effect is expected to be a slight improve- 
ment over existing conditions (Appendix 14) for most wildlife species 
but considerably below the potential that exists if other alternatives 
are implemented. This alternative would not accomplish the wildlife 
objectives for CMR. 

With the following exceptions, there would be the same recreational 
impacts as envisioned with the Proposed Action alternative. Development 
of a major backcountry (nonmotorized) trail as well as establishment of 
primitive campsites and sport fishing access sites at various locations 
throughout the refuge would increase dispersed recreation use and result 
in some conflicts with wildlife due to the greater number of people 
using remote sections. 

Construction of a perimeter shoreline scenic road in the vicinity 
of Fort Peck would destroy a significant area of prime elk habitat and 
would probably cause a reduction in the herd. There also would be 
occasional disturbance of sharp-tailed grouse in spring when they use 
dancing grounds. Proper planning and implementation of a refuge trans- 
portation plan would minimize detrimental impacts to wildlife. 


93 


Consequences 
Multiple Use 


RECREATION AND CULTURAL RESOURCES 


Of the five alternatives considered, this alternative would con- 
tribute the greatest amount toward meeting national and regional rec- 
reation requirements and needs identified in the Nationwide Outdoor 
Recreation Plan (Bureau of Outdoor Recreation 1973) and Montana State- 
wide Outdoor Recreation Plan (Montana Department of Fish and Game 
(1978). Recreation objectives approved for CMR would be satisfied. 

Introduction of peregrine falcons would necessitate restriction of 
human disturbance during the breeding season (Snow 1972). Habitat im- 
provements would be minor, therefore wildlife hunting and viewing 
opportunities would not change significantly. 

Forage allocations under the Multiple Use alternative would pro- 
vide an initial reduction in livestock AUMs to allow range recovery in 
several allotments. This would provide visual enhancement of these 
areas as perennial mid-grass species begin to replace perennial short- 
grasses and annual forbs and grasses. Increases in livestock levels to 
7,000-7,500 AUMs on UL Bend NWR would lower pristine qualities of this 
portion of the refuge for some people where no livestock are presently 
grazed. Increased livestock use would increase opportunities for con- 
flict between recreation and livestock grazing on high use recreation 
areas . 

Ripping of dense clay and panspots range sites would cause a 
visual intrusion for a minimum of 3-5 years. Other range developments 
such as interior fencing and construction of new reservoirs could lower 
environmental quality of the refuge for those individuals desiring a 
natural setting. Prescribed burning would result in a lowering of 
visual quality for 1-5 years. 

In addition to those impacts discussed under the Proposed Action 
alternative, there would be increased use resulting from designation of 
a backcountry foot and horse trail running the length of the refuge and 
expansion of low density recreation areas. Expansion of interpretive 
facilities and attendant increases in wildlife-wildlands activities 
would present a more favorable image of the refuge to a greater number 
of people than with any of the other alternatives. 

Due to the larger number of people who would recreate on the refuge 
under this alternative, there would be some conflicts between recrea- 
tionists. With more vehicular traffic on existing and proposed roads 
including a shoreline drive, there would be greater maintenance require- 
ments, increased erosion, and increased conflicts with wildlife. Due to 
increased use of refuge roads, there would be a corresponding increase 
in vehicular travel over roads leading into the refuge, across adjoining 
BLM and private lands, and some additional use of BLM lands for recreation. 
Some increased recreation is expected off the refuge as a result of 
implementation of this alternative. 

SOCIOECONOMICS 

This alternative would reduce AUM's granted to refuge permittees by 
26 percent during the 1978-1990 period, and by 12 percent in the 1991- 
2005 period. The direct loss to the ranchers under this alternative 
averages 2.3 percent in sales or gross income during the 1978-1990 


94 


period. The impact to two high dependency ranchers will be much greater. 
The direct and indirect effects are a loss of $664,830 in sales and 9 
workers during the 1978-1990 period. These direct and indirect losses 
in sales will be reduced to $210,930 a year and 3 workers in the 1991- 
200 5 period . 

Increases in recreation visitation due to the multiple use alterna- 
tive would have a direct plus indirect increase in sales of $651,643 and 
+14 workers in the 1978-1990 period. This increase in sales would 
increase to 1.8 million dollars in the 1991-2005 year period, while 
employment would increase 40 workers. 

The net total effects (sum of the direct plus indirect effects for 
both livestock and recreation) is a small gain in sales of $13,817 and 
an increase of 5 workers in the 1978-1990 period. The combination of 
reduced livestock impacts and rising visitation causes regional sales to 
rise to $1.6 million dollars and 37 workers in the 1991-2005 period. 


95 


Consequences 
Multiple Use 


Table 15. Noneconomic effects. Multiple Use alternative, Charles M. 
Russell National Wildlife Refuge, Montana. 


Present 


situation 

Multiple Use 

(1978) 

1990 2005 


Habitat quality 


Sharp-tailed grouse 

4.6 

4.8 

5.3 

Mule deer 

5.6 

5.9 

6.5 

Pronghorns 

5.2 

6.0 

6.6 

White-tailed deer 

5.4 

5.7 

6.9 

Elk 

6.0 

6.1 

6.4 

Waterfowl 

3.4 

4.5 

7.5 

Development 

Burn (acres) 

0 

400 

1,500 

Plant trees (acres) 

0 

0 

0 

Plant shrubs (acres) 

0 

100 

300 

Soil ripping (acres) 

0 

0 

38,000 

Ponds (acres) 

0 

225 

900 

Fences (miles) 

Exclosure 

0 

2 

10 

Boundary (aprx.) 

50 

60 

72 

Interior 

Unknown 

32 

40 

Water projects (No.) 

Ponds (aprx.) 

150 

167 

227 

Troughs 

13 

23 

26 

Springs 

0 

2 

2 

Visitor days 

FWS 

64,000 

72,000 

88,000 

Other 

293,000 

333,000 

370,000 

Total 

357,000 

405,000 

458,000 

Forage (AUMs) 

Wildlife 

50,000 

58,000 

60,000 

Livestock (active) 

56,524 J 

52,096 

61,260 

Total 

106,524 

110,096 

121,260 

Range condition (%) 

Poor 

1 

1 

1 

Fair 

7 

7 

4 

Good 

74 

74 

80 

Excel lent 

18 

18 

15 


2 0-2.5 = poor, 2. 6-5.0 = fair, 5. 1-7.5 = good and 7.6-10.0 = excellent. 
A precise estimate of acres enclosed/raile of fence is not provided 
due to presently undetermined topography and shape of exclosure. A 
^ general rule of thumb is 40 acres enclosed per mile of fence. 

This figure represents active AUMs; 3584 AUMs are inactive totaling 
60,108 AUMs. 


96 


ALTERNATIVE E 


(No Grazing) 


SOILS -WATERSHED 


Proposed fire management practices would result in opening of 
coniferous forest areas with increased grass and forb levels to retard 
runoff and soil loss. Elimination of grazing and implementing treat- 
ments such as planting and construction of temporary exclosures would 
provide more residual cover and shrub communities which would also 
retard runoff and decrease erosion. There would be no forage allocated 
to livestock under this alternative. 

Soil erosion rates from man-caused actions would be minimal by the 
year 2005, following removal of all livestock from the refuge. Geologic 
erosion on steep or fragile sites would continue but at decreased levels 
because of increased plant and litter cover. It is not known if the 
decreased rates of erosion on these fragile sites would constitute a 
significant difference from present rates. 

Soil erosion from overland runoff and wind is expected to decrease 
because of increased plant or litter cover. Bare ground exposed on more 
favorable range sites such as clayey, sandy, silty, or overflow, could 
be expected to average 15 percent or less by 1990, and 5 percent or less 
by the year 2005. These levels have been achieved on similar range 
sites presently excluded from livestock use, whereas estimates of sam- 
ples of grazed range sites in 1978 indicated an average of from 20-42 
percent bare ground on the respective range sites for all samples taken. 

Soil erosion rates would be minimal as they relate to accelerated 
erosion. Soil ripping practices plus increased plant and litter cover 
levels following removal of all livestock from CMR would provide attain- 
ment of the highest potential soils and watershed conditions on a 
refuge-wide basis. However, increased litter cover would provide for 
greater risk of uncontrollable wildfire. Litter accumulation may pro- 
vide the necessary fuel for burns which may be hot enough to kill peren- 
nial grass species. Uncontrolled wildfires could conceivably result in 
massive soil losses through erosion, especially if vegetation is killed. 

About 10,000 acres of accessible dense clay and panspots range 
sites would be treated by the year 200b. Such treatment would provide 
greater water infiltration, less overland runoff, a significant increase 
(two- to five-fold) in vegetative production, and improved soil proper- 
ties. The increased vegetative cover, in addition to reducing erosion, 
would provide additional forage and security cover for wildlife. 

Interior fences would be allowed to deteriorate or would be removed 
and reservoirs on marginal sites allowed to fill with silt. Gradual re- 
duction in grazing through the year 200 5 would provide an accelerated 
rate of return to natural conditions with man-caused erosion effectively 
eliminated by the year 2005. Geologic erosion would continue actively 
on the more fragile and susceptible sites such as breaks and shale 
areas. 


97 


Consequences 
No Grazing 


The refuge boundary fence would serve to prevent all livestock use 
on refuge lands and maintain soil and watershed quality. No significant 
detrimental impacts to wildlife are expected to result from boundary 
fence construction. Impacts of recreation and cultural resources would 
be the same as for the Proposed Action alternative. 

WILDLIFE HABITAT-RANGE RESOURCES 


Lack of residual vegetation for cover and food is limiting to 
several species of wildlife. Complete lack of grazing would provide 
adequate amounts (8-10 inches) of residual vegetation on almost all 
suitable sites. This would mean adequate nesting and hiding cover for 
sharp-tailed grouse, other ground nesting birds, and some small mammals 
and forage for elk, mule deer, and pronghorns. However, species such as 
the prairie dog would show a decline from the No Grazing action. 

Reintroduction of black-footed ferrets and peregrine falcons would 
add diversity to wildlife on the refuge and help in re-establishing 
these endangered species. 

Elimination of grazing and associated disturbances would mean a 
reduction in the number and size of prairie dog towns. As a result, 
it would reduce habitat for such unique species as burrowing owls and 
mountain plovers as well as the potential success of swift fox and 
black-footed ferret reintroductions. It would provide more favorable 
conditions for bighorn sheep (Eichhorn and Watts 1976). There would be 
a maximum percentage of suitable sites for sharp-tailed grouse to nest, 
and thus, a probable increase in sharp-tailed grouse. Habitat to sup- 
port white-tailed deer would be excellent. Waterfowl numbers would 
increase somewhat while habitat to support pronghorns would decrease. 
Small mammals and birds show varied results to different grazing levels 
or lack of grazing depending upon their respective habitat requirements. 
Ground squirrels are discouraged from using heavy stands of tall grasses 
(Smith 1940) . Pocket gophers prefer deteriorated range because of 
greater numbers of tap-rooted and bulbous-rooted plants (Buechner 1942) . 
Meadow mice favor climax or near climax conditions (Vories and Taylor 
1940) . 

Smith (1940) found that nongame birds quickly disappeared from 
overgrazed lands in the mixed grass prairie. Weatherill and Keith 
(1969) found that moderate grazing may improve habitat for such species 
as mountain plovers and western meadowlarks. Owens and Myres (1973) 
found that disturbance of a fescue grassland by mowing or cattle grazing 
reduced or eliminated Bairds' sparrow and Sprague's pipit, but did not 
affect savannah or clay-colored sparrows and western meadowlarks and 
permitted ingress of prairie horned larks and chestnut-collared long- 
spurs . 

Range deterioration may reduce populations of some native birds and 
allow an increase of insects that damage residual grass (Daubenmire and 
Daubenmire 1968). Page et al. (1978) found that Nevada and California 
habitats had generally lower, densities and numbers of species of nongame 
wildlife on grazed versus ungrazed areas. 


98 


Residual cover for sharp-tailed grouse nesting would eventually be 
at a level of 8-10 inches on 95-100 percent of all suitable sites by 
elimination of livestock grazing. Some areas would have 10-12 inches of 
residual cover. This would greatly accelerate overall habitat improve- 
ment from fair to excellent for this species. 

Effective management of sagebrush flats would be limited with no 
livestock grazing. Removal of livestock would eliminate a key tool in 
manipulation of sagebrush communities because of livestock preference 
for grasses and forbs over browse. The shrub canopy in these stands 
would be expected to decrease with time to canopy cover ranges of 5-20 
percent. Grass and forb enhancement would occur. Value as critical 
winter range could decline slightly as a result of reduction in sage- 
brush stands, while increased forb and grass production would make these 
communities more valuable for some wildlife during remaining seasons. 

This option would provide maximum benefit to wildlife species 
associated with climax conditions. Those species associated with serai 
stages would suffer from loss of habitat, and populations would suffer 
moderate declines. However, wildlife objectives would be met. 

Because livestock grazing would be eliminated on the refuge, ad- 
jacent landowners might stock their own lands above carrying capacity 
levels. This heavy stocking could cause the most severe degradation of 
wildlife habitat on adjacent lands for any of the five alternatives. 

Range objectives would not be met with this alternative. 

No livestock grazing would provide optimal rates of return to 
climax conditions by the year 2005. Minor drainages that have the 
potential of supporting riparian communities would do so under this 
alternative. Construction of temporary fences to exclude wildlife until 
shrubs are re-established, and planting of shrubs would improve riparian 
conditions on treated sites. The final result would be an increase in 
habitat condition from good to excellent on sites capable of supporting 
a riparian community. The same would apply to upland ponds as suitable 
waterfowl habitat. 

Key shrubs are lacking for use as food as well as cover and perches. 
No livestock grazing, when combined with prescribed burning-browse 
reseeding (11,300 acres) and seedling planting (500 acres), would pro- 
vide excellent opportunities to reach desired shrub community levels. 
Desired shrub levels would be met or exceeded on 60 percent of poten- 
tially suitable sites by the year 2005 and on all suitable areas in 40- 
50 years. 

Prescribed burning would increase deciduous browse which is vital 
as a source of mule deer winter food. K. Hamlin (personal communica- 
tion) indicated forbs are important to mule deer in all snow-free 
seasons. Eichhorn and Watts (1974) found that shrub and forb production 
on wildfire burns in the Missouri River breaks was substantially higher 
than on unburned control areas. Burning to increase shrubs and forbs 
would help increase ability of 2 the habitat to support over-wintering 
populations of over 12 deer/mi . 

Effects of increased burning in nonsagebrush communities and re- 
duced levels of sagebrush on sagebrush flats would be somewhat off- 
setting to mule deer habitat. Deer would tend to make higher use of 
deciduous shrubs enhanced by burning for winter forage to replace sage, 
which is presently heavily used in the winter. 


99 


Consequences 
No Grazing 


Tree planting would occur on 4,700 acres with impacts similar to 
the Intensive Wildlife Management alternative. Overall habitat quality 
would increase 13-144 percent over the 20-year period, depending upon 
species evaluated (Appendix 14). The refuge contains only a portion of 
the biological unit for elk; therefore, the elk population would not 
increase significantly, as it would be controlled by off-refuge factors. 

All riparian areas would improve to their maximum potential along 
intermittent and continuous streams and would improve the fishery re- 
source more than any other alternative. 

Impacts for all animal damage control would be the same as the No 
Action alternative. 

Federal livestock AUMs would be reduced by about 10 percent/year 
until the total elimination of livestock occurred. All state and pri- 
vate AUMs would be eliminated by the year 2005. All forage would be 
available for wildlife to fulfill habitat needs for food and cover by 
the year 2005. Habitat quality resulting would be such that it could 
support ^ sharp-tailed grouse spring breeding bird density of 35-40 
birds/mi . In addition, grass and especially forb levels, would in- 
crease for use by pronghorns, sage grouse, and mule deer. 

Impacts to wildlife habitat of implementing this alternative would 
be somewhat similar to the Proposed Action alternative, except that all 
AUMs would be provided to wildlife for food and cover. No prescription 
grazing by livestock would be allowed, and this would limit the scope of 
habitat management treatments to benefit wildlife species associated 
with serai stages of vegetation. The scope of improvements proposed 
would be less than for Intensive Wildlife Management. There is less 
likelihood that all wildlife objectives would be met or exceeded with 
this alternative. 

With no forage allocated to livestock, it is possible that overall 
site productivity and vigor would decline slightly on a refuge-wide 
basis, since litter accumulations would lower the rate of seedling 
establishment and stifle new shoot growth on mature plants. However, a 
study of livestock exclosures in the Nichols Coulee area of the refuge 
does not lend support to one theory (Cosby 1978) that nonuse results in 
range stagnation. Clipping studies of livestock exclosures on the 
refuge protected from livestock grazing for approximately 12 years 
reveal no such range stagnation from nonuse. These excluded areas in- 
stead have higher productivity than similar sites which are grazed by 
livestock under a rest-rotation grazing system (Oldemeyer et al. 1980). 

Ripping as much as 10,000 acres of dense clay and panspots range 
sites would improve vegetative productivity and residual cover levels 
for wildlife. 

Impacts of recreation on wildlife habitat-range resources would be 
the same as described under the Proposed Action. 

Short and long term vegetative productivity would be optimized by 
implementation of this alternative. Overall wildlife habitat quality 
would be optimized for climax habitat conditions and lowered signifi- 
cantly in terms of habitat diversity. 


100 


RECREATION AND CULTURAL RESOURCES 


As with the Proposed Action, this alternative would contribute an 
intermediate amount toward meeting national and regional recreation re- 
quirements and needs identified in the Nationwide Outdoor Recreation 
Plan (Bureau of Outdoor Recreation 1973) and the Montana Statewide 
Outdoor Recreation Plan (Montana Department of Fish and Game 1978). 
Recreation objectives identified for CMR would be met. 

Introduction of peregrine falcons would necessitate curtailment of 
human disturbance during the breeding season (Snow 1972) in three small 
areas. However, these areas are in the backcountry and presently re- 
ceive only limited public use. Habitat management would provide some 
increased viewing and hunting opportunities. Effects of forage allo- 
cations would be similar to those provided under the Intensive Wildlife 
Management alternative, except that complete removal of livestock would 
enhance aesthetic qualities of the refuge for some recreationists. The 
complete removal of livestock from refuge lands would cause adverse 
reaction from adjacent landowners; they would close more of their land 
to public use. 

Removal or deterioration of all existing internal range improve- 
ments would improve visual quality for wildlife-wildlands recreation. 
Impacts from ripping would primarily be associated with furrowing on 
upper soil horizons. These effects would last a minimum of 3-5 years. 
Prescribed burning would result in a lowering of visual quality for 1-5 
years . 

Impacts of this alternative would be about the same as those dis- 
cussed for the Proposed Action. However, the primary difference between 
the two alternatives would be a small improvement in the quality of the 
recreation experience under the No Grazing alternative due to a reduc- 
tion in conflicts between livestock and humans where they exist. Also, 
cultural resources would be subject to less disturbance, resulting in 
greater protection of sites and structures. 

SOCIOECONOMICS 


Federal AUMs would decrease from 60,108 in 1978 to 30,000 in 1990. 
AUMs would be reduced to zero between 1990-2005. Direct effects of 
these reductions on refuge ranchers is a loss in gross income of sales 
of $567,000 or 5.3 percent loss in sales on the average during the 197 8— 
1990 period. These adverse impacts would increase the loss in sales to 
1.2 million dollars, averaging 10.5 percent during the 1991-2005 period. 

Obviously, the eleven highly dependent ranchers would be adversely 
affected to a substantial degree. Of the eleven economically viable 
high dependence ranchers, the largest individual imact would be a 74 
percent reduction in sales if the No Grazing alternative was adopted. 

The next largest individual impact would be a 60 percent reduction in 
sales . 

The direct and indirect effects of the livestock portion of the No 
Grazing alternative would be a reduction in regional sales of 1.5 million 


101 


Consequences 
No Grazing 


Table 16. Noneconomic effects. No Grazing alternative, Charles M. 
Russell National Wildlife Refuge, Montana. 



Present 

situation 

(1978) 

No 

1990 

Grazing 

2005 

Habitat quality^ - 

Sharp-tailed grouse 

4.6 

6.8 

8.6 

Mule deer 

5.6 

7.0 

7.5 

Pronghorns 

5.2 

5.9 

6.3 

White-tailed deer 

5.4 

6.8 

7.9 

Elk 

6.0 

7.0 

7.8 

Waterfowl 

3.4 

6.0 

8.3 

Development 

Burn (acres) 

0 

2,800 

11,300 

Plant trees (acres) 

0 

1,175 

4,700 

Plant shrubs (acres) 

0 

125 

500 

Soil ripping (acres) 

0 

0 

10,000 

Ponds (acres) 

0 

0 

0 

Fences (miles) 

Exclosure 

0 

2 

6 

Boundary (aprx.) 

50 

50 

450 

Interior 

Unknown 

0 

0 

Water projects (No.) 

Ponds (aprx.) 

150 

150 

150 

Troughs 

13 

13 

13 

Springs 

0 

0 

0 

Visitor days 

FWS 

64,000 

71,000 

74,000 

Other 

293,000 

327,000 

361,000 

Total 

357,000 

398,000 

435,000 

Forage (AUMs) 

Wildlife 

50,000 

80,000 

130,000 

Livestock (active) 

56,524 J 

30,000 

0 

Total 

106,524 

110,000 

130,000 

Range condition (%) 

Poor 

1 

1 

1 

Fair 

7 

7 

4 

Good 

74 

67 

15 

Excel lent 

18 

25 

80 

2 0-2.5 = poor, 2. 6-5.0 

= fair, 5. 1-7.5 = good 

and 7.6-10.0 = excellent. 

A precise estimate of 

acres enclosed/mile of 

fence is 

not provided 

due to presently undetermined topography and 

shape of 

exclosure. A 

^ general rule of thumb 

is 40 acres enclosed per mile of 

fence . 

This figure represents 

active AUMs; 3584 AUMs 

; are inactive totaling 


60,108 AUMs. 


102 


dollars and a loss in employment of 21 workers during the 1978-1990 
period. These losses would increase to 2.9 million dollars and a loss 
of 43 workers in the 19 91-200 3 period . 

Direct and indirect effects on recreation and tourism in sales is 
positive. Direct plus indirect sales would increase by $271,518, and 
employment would increase by 6 workers in the 1976-1990 period. During 
the 1991-2005 period, direct plus indirect effects would increase sales 
$597,340 and employment of 13 workers. 

The net total effect (sum of livestock and recreation direct plus 
indirect effects) is a loss of 1.2 million dollars in sales and 15 
workers in the 1978-19 90 period . This adverse effect increases to 2.398 
million dollars and a loss of 30 workers in the 1991-2005 period. The 
change in regional employment is less that 1 percent. 


103 







































































































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104 


References 


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. 1978. Personal communication. Assoc. Professor of Wildl. 

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Nielson, L. S. 1978. The effects of rest-rotation grazing on the 
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117 


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. 1978b. Waterton Lakes National Park, Waterton visitor 

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Peterson, J. G. 1970. The food habits and summer distribution of 

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Planz, T. 1979. Personal communication. Wildl. biologist. Fish and 
Wildl. Serv., Bowdoin NWR, MT. 


118 


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. 1979. The effect of coyotes on big game populations in 

Montana. Job Proj. Rept., W-120-R-10. Helena. 28pp. 

Range Term Glossary Committee. 1974. A glossary of terms used in 
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Robbins, C. S. , B. Bruun and H. S. Zim. 1966. A guide to Field 
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Rogers, J. 1978. Personal communication. Soil scientist, Soil Con- 
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Schmidt, J. 1979. Reconnaissance geologic and hydrologic report on 
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Severson, K. E. 1966. Grazing capacities and competition of pronghorn 
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123 


VI. CONSULTATION AND COORDINATION 






Consultation 


VI. CONSULTATION AND COORDINATION 


Public participation during this EIS process began in 1977, when a 
group with diverse interests and backgrounds in natural resources toured 
the refuge and provided management recommendations. A steering com- 
mittee was established with members comprised of representatives from 
BLM, MDFW&P, COE, MDSL, FWS , and Montana State Department of Natural 
Resources. This steering committee has been involved throughout the 
planning and EIS process. 

Public meetings were held in several Montana cities in April 1978 
to determine significant issues on the refuge and to get public involve- 
ment in formulating long range goals for the refuge. Additional meetings 
were held by COE in June 1979, and joint meetings involving both COE and 
FWS were held in September 1979 to obtain public participation immediately 
prior to EIS preparation. Additional agency and public participation 
will be obtained as part of the formal EIS review process. 

The EIS has been provided to several agencies and organizations, 
many of whom have already contributed substantially to its preparation 
(Table 17). Additionally, 950 copies have been sent to legislators, 
interested individuals, media, and local libraries. 

Table 17. Agencies and organizations which provided comments on the 
draft EIS, Management of Charles M. Russell National Wildlife Refuge, 

Mont ana . 


Agencies 


Members of Congress 


U.S. Senator Max Baucus 

U.S. Senator John Melcher 

U.S. Representative Ron Marlenee 

Montana State Senator Mark Etchart 

Federal Agencies 


Advisory Council on Historic Preservation 

Charles M. Russell NWR Advisory Committee 

Department of Agriculture, Soil Conservation Service 

Department of the Air Force 

Department of the Army, Corps of Engineers 

Department of Commerce, National Oceanic and Atomospheric Administration 
Department of Housing and Urban Development 
Department of Interior 

Bureau of Land Management 
Geologic Survey 

Heritage Conservation and Recreation Service 
National Park Service 
Department of Transportation 
U. S. Coast Guard 
Environmental Protection Agency 


124 


State Agencies or Affiliates 


Montana Cooperative Extension Service 
Montana Department of Fish, Wildlife, and Parks 
Montana Department of Livestock 

Montana Department of Natural Resources and Conservation 

Montana Department of State Lands 

Montana Historical Society 

Montana Public Lands Council 

Montana State University 

Office of the Governor, Montana 

Organizations and Local Agencies 

American Wilderness Alliance 

Animal Protection Institute of America 

Defenders of Wildlife 

Ecology Center of Southern California 

Fort Peck Cabin Association 

Garfield County Commercial Club 

Garfield County Commissioners 

Garf ield-McCone Legislative Association 

Glasgow Chamber of Commerce and Agriculture 

Humane Society of the United States 

Last Chance Audubon Society 

Lewistown Bowhunters Association 

Miles City Area Chamber of Commerce 

Montana Association of Conservation Districts 

Montana Association of State Grazing Districts 

Montana Chapter, Wildlife Society 

Montana Natural Resource Clinic 

Montana Stockgrowers Association, Inc. 

Montana Trappers Association 
Montana Wilderness Association 
Montana Wildlife Federation 
National Audubon Society 
National Cattlemen's Association 
National Wildlife Refuge Association 
National Woolgrowers Association 
Natural Area Council 

Natural Resources Defense Council, Inc. 

The Sierra Club 

Valley County Development Council 
Wilderness Society 

Wolf Point Chamber of Commerce and Agriculture 


125 


SUMMARY OF COMMENTS RECEIVED FOLLOWING REVIEW OF THE FIRST DEIS 


A total of 396 letters was received during or after the comment period 
which ended on December 5, 1980, although letters received after that 
deadline were also accepted. Of the total letters received, 4 were from 
legislators, 25 from Federal and State agencies, 33 from various organi- 
zations, and 334 from individuals. Included in the letters received from 
individuals were 196 which were almost identical to that of Ms. Cindy 
Davis, 53 almost identical to that of Mr. and Mrs. Adams, and 57 similar 
to that of Mr. Walter Collins. Of these three groups, the letters of Ms. 
Davis, Mr. and Mrs. Adams, and Mr. Collins were considered representative 
and are the only ones printed. 

Responses were required to many of the letters. These letters, along with 
the responses, are printed at the end of this document. Also printed are 
letters that did not require a response. Letters are arranged in the 
following order: government agencies, legislators, state agencies, 

organizations, and individuals. Statements in each letter requiring a 
response are numbered in consecutive order on the right-hand side. The 
responses which immediately follow the letter correspond to these numbers. 

Public hearings were held on October 28, 29, 30, and November 3, 1980, to 
receive comments on the DEIS. These hearings were held in Missoula, 
Lewistown, and Glasgow, Montana, and Washington, D.C. A total of approx- 
imately 300 persons attended these hearings, and 49 statements were 
presented . 

Transcripts of the hearings, all unprinted correspondence, and attachments 
to letters not printed are on file at U.S. Fish and Wildlife Service, 
Wildlife Resources, P.0. Box 25486, Denver Federal Center, Denver, CO 
80225. 


SUMMARY OF CHANGES FROM THE FIRST DEIS 

Editorial and factual changes have been made throughout the text as a 
result of the draft review process. Tables have been corrected where 
necessary, and in some instances, moved to more advantageous locations. 

Three major changes in the new DEIS include: 

The economics have been reevaluated, and the text including 
Appendices has been rewritten to more accurately reflect the 
expected impacts. 

The Proposed Action has been clarified regarding prescription 
grazing by allotment. 

The planning process and methods utilized for arriving at grazing 
recommendations have been explained in greater detail to 
facilitate understanding and review. 


126 




VII. APPENDICES 








VII. APPENDICES 


Appendix 1. Section 7 evaluation, Charles M. Russell National Wildlife 
Refuge, Montana. 

Alternatives in this EIS may affect one to three endangered species 
black-footed ferrets, peregrine falcons, and bald eagles. Section 7 of 
the Endangered Species Act states that all federal agencies shall con- 
sult with the Secretary of the Interior on the following items: 1) 

review and utilize existing programs to further the purposes of the act; 
2) carry out programs for the conservation of endangered or threatened 
species; and 3) ensure that their actions do not jeopardize such species 
or result in modification or destruction of their critical habitat. 

This consultation involves filling out standard Section 7 forms. 
These forms are then forwarded through administrative channels. Actions 
that are determined not to affect endangered species can be retained by 
the regional office or forwarded to Washington. Actions that may affect 
endangered species are sent to Washington for review. Actions deter- 
mined to have a significant adverse or beneficial effect on endangered 
species are referred to the Director of FWS for his decision to ensure 
that they and their habitats receive full consideration. The following 
forms are the first step in this Section 7 process. 

No Action alternative 


1. Region: 6 

2. Designation: 6-1-80-C 

(region-area-FY) 

3. Program(s) : refuges and wildlife (R&W) , CMR 

4. Listed species or their critical habitats considered: 

Species are the same within the action area and adjacent to the 
action area. 

Black-footed ferret, American peregrine falcon, and bald eagle. 

5. Name and description: Charles M. Russell National Wildlife Refuge 

Environmental Impact Statement. 

6. Location: Charles M. Russell National Wildlife Refuge, Montana. 

7. Objectives of the action: 

a. Maintain habitat for black-footed ferrets. 

b. Monitor peregrine falcon use of wintering areas near Fort Peck. 

c. Maintain existing migration habitat for bald eagles. 

8. Explanation of impacts of action on listed species or their critical 
habitats (attach supporting biological data) : 

a. None. No ferrets are known to occur and their habitat is secure 


127 


Appendix 1 


Appendix 1. (Cont’d.) 


b. None. Current use is by migrants that utilize migrating ducks 
and small passerines as a food source. 

c. None. 


9. Conclusion: 

Black-footed ferret 
American peregrine falcon 
Bald eagle 


May Affect Will Not Affect 

X 

X 

X 


10. Recommendation (including action modification): 

Continue monitoring existing use by peregrine falcons and bald 
eagles . 


Proposed Action alternative 

1. Region: 6 

2. Designation: 6-1-80-C 

(region-area-FY) 

3. Program(s) : R&W, CMR 

4. Listed species or their critical habitats considered: 

Species are the same within the action area and adjacent to the 
action area. 

Black-footed ferret, American peregrine falcon, and bald eagle. 

5. Name and description: Charles M. Russell National Wildlife Environ- 

mental Impact Statement. 

6. Location: Charles M. Russell National Wildlife Refuge, Montana. 

7. Objectives of the action: 

a. Maintain habitat for and reintroduce a minimum of six 
pairs of black-footed ferrets on six or more prairie 
dog towns as soon as ferrets are available. 

b. Reintroduce peregrine falcons and maintain two peregrine 
falcon eyries by 1990 and a third by the year 2005. 

c. Maintain existing migration habitat for bald eagles and 
determine feasibility of establishing a breeding 
population on CMR. 

8. Explanation of impacts of action on listed species or their 
critical habitats (attach supporting biological data) . 

a. Black-footed ferrets could be managed, protected, and 
propagated on CMR. Their habitat, prairie dog towns, 
would remain static or increase slightly to fulfill 
the ferrets’ habitat requirements. 


128 


Appendix 1. (Cont'd.) 


b. Peregrine falcons would be managed, protected, and 
propagated. CMR would provide an excellent area to 
reintroduce them. Habitat for nesting would not 
change, but peregrines' food sources would be increased 
as a result of more residual ground cover which would 
allow more ground nesting passerines. 

c. If areas are identified, management actions could be 
taken to enhance bald eagle nesting. 

9. Conclusion: May Affect Will Not Affect 

Black-footed ferret X 

American peregrine falcon X 

Bald eagle X 

10. Recommendation (including action modification): 

Accomplish objectives by the year 2005. 

Intensive Wildlife Management alternative 

1. Region: 6 

2. Designation: 6-1-80-C 

(r egion-area-FY) 

3. Program(s) : R&W, CMR 

4. Listed species or their critical habitats considered: 

Species are the same within the action area and adjacent 
to the action area. 

Black-footed ferret, American peregrine falcon, and bald eagle. 

5. Name and description: Charles M. Russell National Wildlife 

Refuge Environmental Impact Statement. 

6. Location: Charles M. Russell National Wildlife Refuge, Montana. 

7. Objectives of the action: 

a. Maintain habitat for and reintroduce a minimum of six 
pairs of black-footed ferrets on six or more prairie 
dog towns as soon as ferrets are available. 

b. Reintroduce peregrine falcons and maintain two peregrine 
falcon eyries by 19 90 and a third by the year 2005. 

c. Maintain existing migration habitat for bald eagles and 
determine feasibility of establishing a breeding popula- 
tion on CMR. 

8. Explanation of impacts of action on listed species or their 
critical habitats (attach supporting biological data) : 


129 


Appendix 1 


Appendix 1. (Cont'd.) 

a. The black-footed ferret, as an endangered species, 
could be managed, protected, and propagated on CMR. 

Their habitat, prairie dog towns, would remain static 
or decrease slightly. 

b. The peregrine falcon would be managed, protected, and 
propagated. CMR would provide an excellent area to 
reintroduce the species. Habitat for nesting would 
not change but the peregrines' food source would be 
increased as a result of more residual ground cover 
which would allow more ground nesting passerines to 
be available as a food source. 

c. Cottonwood trees could be planted to provide nesting 
sites along the shoreline on Fort Peck Reservoir in 
protected bays and given special attention (protection, 
water, shade, fence) until they are 5-10 years old. The 
annual fluctuation in reservoir levels may prevent trees 
from becoming established. Cattle use may destroy the 
trees before they become established. Artificial 
nesting structures could be used until the trees are 
tall enough. 


9. Conclusion: 

Black-footed ferret 
American peregrine falcon 
Bald eagle 


May Affect Will Not Affect 
X 
X 
X 


10. Recommendation (including action modification): 
Accomplish objectives by the year 2005. 


Multiple Use alternative 

1. Region: 6 

2. Designation: 6-1-80-C 

(region-area-FY) 

3. Program(s) : R&W, CMR 

4. Listed species or their critical habitats considered: 

Species are the same within the action area and adjacent 
to the action area. 

Black-footed ferret, American peregrine falcon, and bald 
eagle . 

5. Name and description: Charles M. Russell National Wildlife 

Refuge Environmental Impact Statement. 

6. Location: Charles M. Russell National Wildlife Refuge, Montana. 


130 


Appendix 1. (Cont'd.) 


7. Objectives of the action: 

a. Maintain habitat for and reintroduce one pair of 
black-footed ferrets on one of the larger prairie 
dog towns at UL Bend as soon as ferrets are available. 

b. Reintroduce peregrine falcons and maintain two 
peregrine falcon eyries by 1990 and a third by the year 
200 5. 

c. Maintain existing migration habitat for bald eagles. 

8. Explanation of impacts of action on listed species or their 
critical habitats (attach supporting biological data) : 

a. Only one pair of ferrets could be maintained under this 
option because prairie dog control would be carried out 
as needed. 

b. Peregrine falcons would be managed, protected, and 
propagated. CMR would provide an excellent area to 
reintroduce the species. Habitat for nesting would 
not change but the peregrines' food source would be 
decreased as a result of less residual ground cover 
which would allow fewer ground nesting passerines to 
be available as a food source. 

c. None. 

9. Conclusion: May Affect 

Black-footed ferret X 

American peregrine falcon X 

Bald eagle 

10. Recommendation (including action modification): 

Accomplish objectives by the year 2005. Modify grazing 
in areas of proposed introduction of ferrets and falcons 
so as not to adversely affect each specie's food base. 

No Grazing alternative 

1. Region: 6 

2. Designation: 6-1-80-C 

(region-area-FY) 

3. Program(s) : R&W, CMR 

4. Listed species or their critical habitats considered: 

Species are the same within the action area and adjacent 
to the action area. 

Black-footed ferret, American peregrine falcon, and bald eagle. 

5. Name and description: Charles M. Russell National Wildlife 

Refuge Environmental Impact Statement. 


Will Not Affect 
X 


131 


Appendix 1 


Appendix 1. (Cont'd.) 

6. Location: Charles M. Russell National Wildlife Refuge, Montana. 

7. Objectives of the action: 

a. Maintain habitat for and reintroduce a minimum of 
six pairs of black-footed ferrets on six or more 
prairie dog towns as soon as ferrets are available. 

b. Reintroduce peregrine falcons and maintain two 
peregrine falcon eyries by 1990 and a third by the 
year 200 5. 

c. Maintain existing migration habitat for bald eagles 
and determine the feasibility of establishing a 
breeding population on CMR. 

8. Explanation of impacts of action on listed species or their 

critical habitats (attach supporting biological data) : 

a. The black-footed ferret, as an endangered species, 
would be managed, protected, and propagated on CMR. 

Their habitat, prairie dog towns, would decrease 
slightly because no grazing would occur to help 
retard vegetative growth around dog towns. 

b. The peregrine falcon would be managed, protected, 
and propagated. CMR would provide an excellent area 
to reintroduce the species. Habitat for nesting would 
not change but the peregrines' food source would be 
increased as more residual ground cover is provided to 
enhance habitat values for such prey as passerine birds. 

c. If areas are identified, management actions could be 
taken to enhance bald eagle nesting. 

9. Conclusion: May Affect Will Not Affect 

Black-footed ferret X 

American peregrine falcon X 

Bald eagle X 

10. Recommendation (including action modification): 

Accomplish objectives by the year 2005. 


132 


APPENDIX la 

United States Department of the 

\ IS 1 1 AM ) Wll 1)1 II I SI RVICT 
WASH INCi I ON. I).C. 20240 

703 . 7 

In Reply Refer To: 

FWS/OES 6—80—162 Sly - c 



Memorandum 


Interior 


ADDRESS ONLY THE OIRECIOR 
FISH ANO WILDLIFE SERVICE 



To: Regional Director, teg ion 6 (ARD/FA) 

’ ; '' ; _/!■«• . , N ' 

From: '' u Director 

Subject: In tra- Service Section 7 Consultation, Management of 

Charles M. Russel ( CMR) National Wildlife tefuge 
Montana (RW 803.7) 


This responds to your Septemter 2, 1980, request for Section 7 consultation 
on the five management alternatives proposed to solve some of the resource 
problems on CMR, relative to the listed black-footed ferret (Mustela nigripes) , 
the bald eagle ( Haliaeetus leucocephalus ) , and the American peregrine falcon 
( Falco peregrinus ana turn ). 

Cn October 29, 1980, we completed an examination of the above action and 
reviewed the biological information provided by you along with information 
available in our files. Daring the course of this consultation, Mike Pramsteller , 
National Wildlife Federation Raptor Information Center, Arlington, Virginia; 

Dan James and Jay Sheppard, Office of Endangered Species; Gerald Craig, 

Rocky Mt. Peregrine Falcon Recovery Team, Leader; Jim Grier, Northern States 
Bald Eagle Recovery Team, Leader; and Bart CVGara and Chris Servheen, Wildlife 
Coop Unit, Missoula, Montana, were contacted. 


A review of the project information and information obtained from the experts 
and other knowledgeable sources on the biology of the listed species indicates 
that the actions of the proposed management alternatives may result in devel- 
oping habitat for black- footed ferrets that is at least equal to that which 
now exists by manipulating grazing patterns to keep prairie dog towns at 
their present level, except for the no grazing alternative under which there 
might be some reduction in the level of prairie dog towns. The general 
tendency of all alternatives (except the no action alternative) to improve 
habitat for wildlife should provide improved conditions for the bald eagle 
and especially the peregrine falcon by improving riparian habitats, and 
thereby increasing the number and variety of avian prey for the latter species. 



iti w i a '80 


-V • n qg -r. 




133 


APPENDIX la (cont’d) 


Appendix la 


The re introduction of black-footed ferrets and the establishment of peregrine 
falcon eyries, as these animals become available, (under all except the no 
action alternative) would contribute to the possibility of eventually recovering 
these species. The no action alternative will at least leave habitat for 
these two species in its present condition. 

Therefore, it is my biological opinion that your action, as proposed, is not 
likely to jeopardize the continued existence of the black- footed ferret, bald 
eagle, or peregrine falcon. 

TO assist you in exercising your authority for the conservation of listed 
species, the following actions are recommended: 

1. Dr. Louis Locke of the National Wildlife Health Laboratory in 
Madison, Wisconsin, is currently conducting a detailed study 

of secondary lead poisoning in raptors, prompted by preliminary 
evidence that raptors may be affected by ingesting lead 
contaminated waterfowl. Any refuge having an incidence or 
suspicion of secondary lead poisoning in raptors should 
immediately contact Dr. Locke at Pi’S 364-5422 or Commercial 
608/264-5422. 

2. Daring waterfowl hunting seasons various means such as signs or 
posters at hunting access points, in blinds, etc., should loe used 
to warn hunters of the possible occurrence of bald eagles and 
peregrine falcons in the area and to help them identify these 
two species. 

3. Once attempts are underway to establish peregrine falcon eyries, 
care should be taken to limit human activities within the vicinity 
of these sites. 

Should this action, as now planned, be modified or altered, or should new 
species be listed that may be affected, you must reinitiate consultation. 


( 



134 


Appendix lb. The Planning Process 


The conclusions reached in regard to wildlife and grazing in the 
Proposed Action require the understanding of the step-by-step process 
and rationale used, progressing from the mission statement to monitoring 
of specific actions taken to reach the objectives. This process is 
summarized here for clarification. 

The mission statement (par. 2, page 4 ) for CMR is based on that of 
the National Wildlife Refuge System. The CMR goals, in priority order 
(page 4 ), are derived from and expand upon the CMR mission statement. 
They are more specific in stating the purposes and activities desirable 
and permitted on CMR. From these goals were derived the even more 
specific objectives, also in priority order (pages 5 and 6 ), often 
quantified and providing desired end points. These end points were 
sometimes modified following determination of habitat potential and 
resolution of conflict that came later in the planning process. The 
wildlife objectives drive the planning process, dominate the other 
objectives, and may modify or preclude the others if conflicts arise 
that cannot be resolved in any other way. In the case of the Proposed 
Action, additional policy constraints (par. 3, page 9) were imposed by 
Management . 

With the above guidelines and constraints, a list of important and 
indicator wildlife species , both game and nongame, were selected (Appen- 
dix 2). The present value of the refuge for these species, and the 
deficiencies of the habitat for each of these, was determined for the 
refuge through sampling, using the 1976 Habitat Evaluation Procedure 
(HEP). Habitat potentials for the selected species were estimated, 
based upon interpretation of soils information (Appendix 7, pages 
166-170), range site and condition survey data (Appendices 8 and 9, 
pages 171-178), HEP criteria (Appendix 2, pages 137-157), literature 
review, and information on wildlife population densities and distribu- 
t ion. 

From this point, it was possible to envision a desired, general 
habitat model for the refuge as a whole that would permit achieving the 
best mix of wildlife objectives. This required some trade-offs among 
the selected wildlife species (what is best for one species is not 
necessarily best for another). These trade-offs were weighted in favor 
of those species judged to be the more important ones on CMR. It quickly 
became clear that maximum diversity and interspers ion of habitat would 
best accomplish a desirable mix of wildlife when viewed for the refuge 
as a whole. The habitat model included such concepts as variety of 
habitat types, edge, interspers ion of habitat types, maximum amounts of 
deciduous shrubs, and varying degrees of utilization of forage. 

The next step was to analyze possible ways to achieve the conditions 
envisioned in the desired habitat model and select those that would do 
the job. Wildlife foraging, livestock grazing, fire, planting, and 
mechanical manipulation were considered. In the case of the Proposed 
Action, freedom to choose methods of achieving the habitat model on the 
ground was constrained by policies (par. 3, page 9 ). It was concluded 
for the Proposed Action that light, seasonal livestock grazing at various 
times of the year and in various places, along with limited use of fire 
and planting, would accomplish the objectives within policy constraints. 


135 


Appendix lb 


Appendix lb. (Cont’d.) 

During the same time as the above was being done, a range site and 
condition survey (Appendices 8 and 9) was made in accordance with Soil 
Conservation Service procedures which resulted in a standard computation 
of existing AUMs of forage. The AUMs derived from this method were then 
subjected to a slope/water matrix (Appendix 15, pages216-221) to more 
realistically determine availability of forage to livestock. 

When the results of this process, along with small, additional soil 
factor reductions, were analyzed, it became clear that in most cases the 
resultant AUMs represented light stocking rates, so further adjustments 
for stocking would generally not be needed to conform to the habitat 
model. However, a few additional reductions were made to meet specific 
wildlife needs in key areas. 

The next step, upon receiving the Record of Decision, will be to 
develop Habitat Management Plans , largely based upon grazing allotment 
boundaries, to achieve wildlife objectives. These plans will be in con- 
formity with the guidance provided in the EIS, but, unlike the EIS, will 
be site specific and designed to meet the particular wildlife needs 
within the area of concern. They will be developed in cooperation with 
involved landowners, BLM, and other affected parties. 

The final step will be to monitor the progress of the Habitat 
Management Plans towards achieving refuge objectives, and making ad- 
justments as they are needed. 


136 


Appendix 2. Habitat evaluation procedures and values on Charles M. 
Russell National Wildlife Refuge, Montana. 

INTRODUCTION 


The habitat evaluation procedures (HEP) used in this document 
originated with FWS to gather information for planning and decision 
making. Data on habitat needs of various indicator species were col- 
lected from scientific publications, documented research findings, field 
notes, and professional judgments. Through this process of documenta- 
tion, the best information available on species habitat needs was com- 
piled. This data base is subject to change as new information becomes 
available, but existing knowledge provides a sound scientific basis from 
which to proceed. 

The system of analysis evaluates criteria on a scale of 1 to 10, 
with 10 being an ideal condition. Because habitat evaluation criteria 
are derived from locations with varying climates and soils, the criteria 
value of 10 may not be possible to obtain on CMR. Average annual pre- 
cipitation on CMR is only 10-13 inches, and soils are largely Bearpaw 
shales, which have low production potential. It is important to keep 
these limitations in mind when considering the evaluation criteria. 

METHODOLOGY 


The refuge was flown in June and July 1977 to obtain color infrared 
(CIR) photos at a scale of 1:24000. These photos were interpreted to 
determine vegetative types (Appendix Table 2-A) . One criterion for 
habitat evaluation is that information about a species has to be avail- 
able. The literature was not definitive for all vegetative breakdowns, 
and certain types were combined into the following categories for evalu- 
ation: sagebrush-greasewood-grasslands , ponderosa pine-juniper, and 

grassland-deciduous shrub. Other vegetative types listed were deciduous 
river bottoms and cultivated lands. Ponds were considered portions of 
major vegetative types in which they occurred. 

Representative species were selected for these five vegetative 
types based on the following factors: 1) information available on 

habitat requirements; 2) a good indicator of habitat quality and/or 
represents a group of other species; and 3) economically important. 

Individual sample sites were selected from a table of random 
numbers. Two digit numbers were selected corresponding to ranges and 
townships. All habitat types within the selected section were sampled. 
Additional samples were taken as time permitted to increase sampling 
reliability. At each sample site the following information was listed: 
1) unit numbers, 2) general vegetative type, 3) date, 4) legal descrip- 
tion, 5) subtype, and 6) evaluator’s name. Each habitat component was 
rated on a scale of 1-10 (10 being the best and 1 the worst). Criteria 
with interval values of 1, 4, 7 and 10 are described in Appendix Tables 
2-B through 2-G for the seventeen species sampled. 


137 


Appendix 2 


Appendix 2. (Cont'd.) 

Assignment of values 1-10 for individual criteria was based on a 
combination of observations and actual measurements. Periodic measure- 
ments were taken to verify observations, thus maintaining confidence in 
evaluation. Then two overall values were listed. The first was a 
biological judgment from the evaluating team and the second was the 
numerical average of the listed criteria. If differences of more than 
2.5 units existed between the two overall values, reasons for this were 
documented on the field sheets. The two values were generally com- 
parable. Where discrepancies occurred, ratings were modified based on 
both the actual rating and the biologist's comments. The total number 
of sample values was averaged for each species by individual criteria 
and overall value for respective vegetative types. For example, in the 
sage-gr easewood-grassland , all mule deer values for condition of browse 
were summed and divided by the number of samples to get a value of 4.9 
(Appendix Table 2-C) . In the same manner all overall mule deer values 
in this type were summed and divided by the number of samples to get a 
value of 4.7. 

The terms poor, fair, good, and excellent are referred to through 
the narrative in relation to HEP criteria. The four terms indicate the 
following range of HEP values: poor, 1.0-2. 5; fair, 2. 6-5.0; good, 5.1- 

7.5; and excellent, 7.6-10.0. 

These terms could be applied to individual criteria or overall 
values. If a species was evaluated in more than one vegetative type, 
a weighted average was derived based on the percentage of the respective 
habitat type in which the species was found. For example, in the pon- 
derosa pine-juniper type, the overall value for sharp-tailed grouse was 
4.5, and in the grassland deciduous shrub type it was 5.6. The ponderosa 
pine-juniper type occupies approximately 35 percent of the refuge, 
while the grassland-deciduous shrub type occupies about 2 percent of the 
area. Since the ponderosa pine-juniper type covers about 17 times more 
area, the value used for sharp-tailed grouse was derived as follows: 

Sharp-tailed grouse value = (4.5 x 17) + (5.6 x 1) 

18 

= 4.56 
= 4.6 
= fair 


138 


Appendix 2. (Cont'd.) 


Appendix Table 2a. List of vegetative types on Charles M. Russell 
National Wildlife Refuge, Montana. 


1. Big sagebrush-grassland 

2. A. Silver sagebrush bottomlands 

B. Silver sagebrush - sandy upland sites 

3. Ponderosa pine 

4. Douglas fir 

5. Juniper 

6. Deciduous river bottoms (includes ash coulees) 

7. Grassland 

8. A. Tall shrubs - buffaloberry 

B. Shorter shrubs - rose and snowberry 

9. Halophytic shrubs 

A. Greasewood bottomlands 

B. Gr easewood-grasslands 

C. Shadscale 

10. Cultivated lands 

A. Hayland 

B . Dryland 

11. Barren areas 


139 


Appendix 2b 


Appendix 2. (Cont'd.) 

Appendix Table 2b. Sagebrush-grassland vegetative type on Charles M. 
Russell National Wildlife Refuge, Montana. 


Sage grouse habitat criteria and rating values 


-10- 

Interspers ion of grass and sage with areas of dense big sage 
(20-39 percent canopy cover) for use by adults throughout 
the year (Wallestad 1971, Eng and Schladweiler 1972). Areas 
of moderate big sage (10-15 percent) for use by broods (Wallestad 
1971 and Klebenow 1969) . Sage 10-24 inches in height for use 
throughout the year (Dalke et al. 1963, Martin 1970, Wallestad 
1971) . Ground cover has 10-15 percent canopy cover for forbs 
in spring and summer (professional judgment). Water within one 
mile (professional judgment and inference by Patterson 1952). 

-7- 

Interspers ion of dense and moderate big sage for adults and 
broods as above. Sagebrush is 6-16 inches high. Forbs com- 
prise less than 10 percent of ground cover in spring and 
summer. Water 1-1.5 miles away. 

-4- 

No interspers ion of dense big sage and moderate big sage. 

Sage less than 12 inches in height. Forbs comprise less than 
5 percent of the ground cover in summer. Alfalfa fields 
available within the area (professional judgment). Water 2-3 
miles . 

-1- 

Big sage brush very scattered and less than 10 inches tall. 
Forbs almost nonexistent. Alfalfa fields heavily used. Water 
greater than 3 miles away. 


Golden eagle habitat criteria and rating values 


-10- 

Large tracts (1000 acres or larger) of sage-grassland for 
hunting (McGahan 1968). Cliffs and/or rock outcrops for 
nesting (Snow 1973, Boecker and Ray 1971). Perch sites avail- 
able in the form of snags and/or rock outcrops (Jackman and 
Scott 1975). Sage-grassland with a mixture of sage and grass 
species that provide cover for rodent populations (professional 
judgment). No human disturbance within 1 mile (Snow 1973, 

Fish and Wildlife Service 1976, Boecker and Ray 1971). 

-7- 

Tracts of sage-grassland 500-1000 acres in size. Rock outcrops 
are more limited, but some large cottonwoods occur for nesting. 
Sage-grassland lacks good mixture of sage and grasses resulting 
in smaller rodent populations. Human disturbance within 1/2 
mile of nest. 


140 


Appendix Table 2b. (Cont'd.) 


-4- Small tracts of sage-grassland (250-500 acres) located ad- 

jacent to ponderosa pine forest. Sage-grassland lacks rock 
ledges for nesting and perching. Ponderosa pine provides some 
nest sites. Sage-grassland has vegetation less than 8 inches 
tall resulting in poor cover for rodents. Human disturbance 
within 1/4 mile. 

-1- Sage-grassland is less than 250 acres in size. No nest sites 

available in the sage-grassland. Sage-grassland vegetation is 
less than 5 inches high. Continual human disturbance occurs. 

Pronghorn habitat criteria and rating values 

-10- Sage-grassland with a mixture of big sage, silver sage, 

snowberry, rose, and rabbitbrush (Couey 1946). Succulent 
forbs available in spring and summer (Hoover et al . 1959). 

Silver sage abundant in coulee bottoms and adjacent benches 
for feeding in winter (D. Pyrah personal communication). 
Sagebrush canopy cover of 10-24 percent for use throughout 
the year, and 20 percent or greater for fawning (Bay less 
1969, D. Pyrah personal communication). Rolling terrain 
marked by depressions, ridges, flats, benches, and some breaks 
(Rouse 1959, Hoover et al. 1959). Sagebrush 1-1.5 feet tall 
(Einarsen 1948, and Severson 1966) . 

-7- Sage-grassland with 2-3 species of shrubs as listed above. 

Forbs available in spring. Silver sage less abundant than 
above. Sage canopy cover is a maximum of 15 percent for all 
uses. Sage less than 1 foot tall. Terrain is gently rolling 
but without depressions and breaks. 

-4- Sage-grassland of mostly big sage. Forbs available in wet 

years. Alfalfa fields used in summer (Cole 1956). Silver 
sage very restricted for winter use. Sagebrush canopy cover 
is 10 percent or less for all seasons of use. 1.5-2 feet 
tall. Terrain quite flat; lacking little if any topographic 
relief . 

-1- Rank growth of sagebrush over three feet in height or sage 

extremely sparse. Terrain extensively flat. 

Mule deer habitat criteria and rating values 

-10- Big sage, rubber, and green rabbitbrush abundant for winter 
use (Mackie 1970). Species are in good -excel lent condition 
with little or no hedging (Mackie 1970). Forbs, such as wild 
onion, biscuitroot, and especially yellow sweet clover available 


141 


Appendix 2b 


Appendix Table 2b. (Cont'd.) 

in summer and fall (Mackie 1970). Other shrubs present 
include skunkbrush, rose, snowberry, and creeping juniper 
(may include some Rocky Mountain juniper) (Mackie 1970, 

Allen 1968). Topographic relief in the form of cuts, 
ravines, and/or juniper patches for hiding cover (profes 
sional judgment). Land is deeply dissected (professional 
judgment) . 

-7” Big sage and rabbi thrushes abundant for winter use. Fair- 

good condition with some hedging. Same forbs present, but 
yellow sweet clover is restricted for use. Skunkbrush and 
juniper present. Topographic relief is less pronounced. No 
deep dissection of the land. Less juniper for hiding cover. 

-4- Only big sage present for winter use. It is in fair-good 

condition with moderate hedging. Few forbs present. Little 
sweet clover. Scattered skunkbrush. Rolling hills. No deep 
dissected land. Sparse juniper cover. 

-1- Scattered sage in poor condition and badly hedged. Very few 

forbs. No sweet clover. Lack other palatable browse species. 
Land is flat to gently rolling. No rugged escape cover. 


1 = poor, 4 = fair, 7 = good and 10 = excellent 


142 


Appendix 2. (Cont'd.) 


Appendix Table 2c. Ponderosa pine- juniper vegetative type on 
Charles M. Russell National Wildlife Refuge, Montana. 


Red-tailed hawk habitat criteria and rating values 


-10- 

Ponderosa pine forest that is open (canopy cover less than 
30 percent) (Bent 1937, Jackman and Scott 1975, modified by 
professional judgment) and adjacent to areas of sage-grassland. 
Trees 20-30 feet tall and 8-10 inches DBH for nesting (Bent 
1937, Jackman and Scott 1975, modified by professional judg- 
ment). Sage-grasslands has good mixture of sage, grass, 
and forb species as cover for prey population (professional 
judgment) . 

-7- 

Ponderosa pine has 30-45 percent canopy closure. Adjacent 
sage grassland is 300-400 acres in size. Trees 15-20 feet 
tall, 6-7 inches DBH. Sage-grassland in fair condition as 
cover for prey population. 

-4- 

Ponderosa pine forest having 45-60 percent canopy closure. 
Adjacent to smaller sage-grassland (less than 300 acres). 
Trees 10-15 feet tall and 4-5 inches DBH. Grassland in good 
condition, but little or no sagebrush. 

-1- 

Dense ponderosa pine forest (greater than 60 percent canopy 
cover). No sage-grassland for hunting. 


Elk habitat criteria and rating values 


-10- 

Long narrow coulees that are highly dissected and contain 
mesic sites with dense conifer cover at their head (B. Campbell, 
personal communication). Dense juniper thickets for calving, 
hunting security, and shade (B. Campbell personal communica- 
tion). Topographic relief in the form of cuts, ravines, 
and/or trees for shade and hiding cover (B. Campbell per- 
sonal communication) . Abundant mesic coulees for feeding 
summer and fall (B. Campbell personal communication). Small 
to moderately extensive ridgetops dominated by big sage- 
western wheatgrass in good -excel lent condition for winter- 
spring use (Mackie 1970). Water source every section (B. 
Campbell personal communication). 

-7- 

Fewer long narrow coulees as above. Less dense juniper 
thickets. Rolling topography. Some mesic sites and/or 
yellow sweet clover patches for feeding summer and fall. 
Ridgetops as above in fair-good condition for winter-spring 
use. Water source every two sections. 


143 


Appendix 2c 


Appendix 

Table 2c. (Cont’d.) 

-4- 

No coulees as above. No juniper thickets. Rolling topog- 
raphy. Few mesic coulees and/or clover patches. Winter- 
spring areas in poor-fair conditions. Water sparsely 
distr ibuted . 

-1- 

Lack of topographic relief and vegetative cover. Lack of 
palatable grasses and forbs. Lack of water. 


Sharp-tailed grouse habitat criteria and rating values 


-10- 

North slopes with 10-12 inches of effective residual grass 
cover for nesting (Christenson 1971, Sisson 1976). Shrub 
crown cover of 30-45 percent in coulees (Grange 1948, Ammann 
1957). Shrub coulees with serviceberry , chokecherry, snow- 
berry, wildrose, and buffaloberry (Sisson 1976, Nielsen 1978). 
Shrubs having all terminal leaders alive (professional judg- 
ment) . Grasses and forbs abundant and in good condition be- 
tween forest area (Edminster 1954, and professional judgment). 

-7- 

North slopes with 8-10 inches effective residual grass cover. 
Shrub crown cover 45-60 percent in coulees. Same shrub species 
Shrubs with 75 percent of terminal leaders alive. More grasses 
and less forbs between forest areas. 

-4_ 

North slopes have effective residual grass cover of 6-8 inches 
high. Shrubs in coulees with 20-30 percent crown cover. Some 
deciduous species present but mostly juniper. Deciduous shrubs 
somewhat decadent (50 percent of terminal leaders alive). 
Understory sparsely vegetated. 

-1- 

Residual grass cover less than 6 inches tall. Only juniper 
present and in good condition. Grading into sage-grassland. 


Porcupine habitat criteria and rating values 


-10- 

Ponderosa pine forest with a semi-open canopy (30-60 percent) 
(Costello 1966 and professional judgment). Trees 7 inches or 
greater DBH and 15-20 feet high (Marshall et al. 1962). 
Herbaceous material composes about 50 percent of the ground 
cover (Costello 1966 and professional judgment). Some heavy 
brush, rock piles, or other suitable dense cover is available 
within the habitat for denning (Costello 1966). 

-7- 

Ponderosa pine forest with less than 30 percent canopy cover. 
Herbaceous material composes 25-50 percent of the ground 
cover. Clumps of dense brush and/or rock outcrops are quite 
scattered . 


144 


Appendix Table 2c. (Cont'd.) 


-4- 

Ponderosa pine forest with dense canopy cover (greater 
than 60 percent). Trees more than 30 feet tall. Less than 
25 percent herbaceous ground cover. Single scattered bushes 
and few rock outcrops. 

-1- 

Dense ponderosa pine forest ground cover is primarily pine 
needles. No brush or rock outcrops. 

Mountain 

bluebird habitat criteria and rating values 

-10- 

Ponderosa pine forest that has less than 30 percent canopy 
cover (Jackman and Scott 1975) and two or more snags/acre 
with cavities for nesting (Baida 1975). Ground cover is 
less than 2 feet high (Miller 1970). 

-7- 

Ponderosa pine forest with as much as 60 percent canopy cover. 
Still has several cavities for nesting. Ground cover is up to 
3 feet high. 

(-6- 

Juniper present but grass less than 2 feet tall.) 

-4- 

Ponderosa pine forest with as much as 75 percent canopy 
closure. Few nesting cavities occur. Ground cover is over 
3 feet high. 

-1- 

Closed ponderosa pine forest. Greater than 75 percent canopy 
cover. No nesting cavities. Heavy shrub understory. 


Bobcat habitat criteria and rating values 


-10- 

Forest canopy closure 45-60 percent (professional judgment). 
Moderate brush understory (difficult to see through but 
can be walked through) (Sampson 1967). Scattered rock out- 
crops and ledges (Rollings 1945). This forest may also be 
adjacent to coulees filled with juniper and sagebrush (Young 
1958) . 

-7- 

Canopy closure 30-45 percent and forest understory is be- 
coming dense (difficult to walk through) . Dense clumps of 
scattered juniper may also occur. 

-4- 

Open forest, less than 30 percent canopy cover. Light shrub 
understory. Few rock outcrops. Coulees have little juniper 
or sage. 

-1- 

Scattered trees. Herbaceous understory. No rock outcrops. 


145 


Appendix 2c 


Appendix Table 2c. (Cont'd.) 

Mule deer habitat criteria and rating values 

-10- Interspers ion of ponderosa pine with patches of sage- 

grassland on smaller ridgetops, and along margins of more 
extensive ridges with sage abundant in these areas for winter 
use (Mackie 1970). Forbs (especially yellow sweet clover) 
and skunkbrush available in summer and fall (Mackie 1970). 
Other shrubs as snowberry, rose, and chokecherry also avail- 
able in summer and fall (Mackie 1970, Allen 1968). Shrubs, 
including big sage and rubber rabbitbrush, available in 
winter, in good condition with no hedging (Mackie 1970). 

-7- Interspers ion of ponderosa pine with patches of sage- 

grassland along major ridgetops and sage abundant. Yellow 
sweet clover available in summer. Skunkbrush very sparse. 

Big sage and rubber rabbitbrush available in winter in fair 
condition with some hedging. 

-4- Interspers ion of ponderosa pine with some patches of sage- 

grassland along major ridgetops and sage scattered. Yellow 
sweet clover very scarce as is skunkbrush for summer and fall 
use. Big sage available in winter in poor condition with 
moderate hedging. 

-1- Ponderosa pine on moderate slopes with no sage-grassland 

interspersed. Few palatable forbs or shrubs as above. Those 
present are in very poor condition and heavily hedged. 


1 = poor, 4 = fair, 7 = good and 10 = excellent 


146 


Appendix 2. (Cont'd.) 


Appendix Table 2d. Grassland-deciduous shrub vegetative type on 
the Charles M. Russell National Wildlife Refuge, Montana. 


Sharp-tailed grouse habitat criteria and rating values 


-10- 

North slopes with 10-12 inches of effective residual grass 
cover for nesting (Christenson 1971, Sisson 1976). Shrub 
coulees of 30-45 percent crown cover (Grange 1948, Ammann 
1957) and 6-12 feet high for brooding and roosting (Sisson 
1976, Nielsen 1978). Shrubs are mostly serviceberry , choke- 
cherry, snowberry, wild rose, and buffaloberry (professional 
judgment). Grasses and forbs abundant and in good condition 
between shrub areas (Edminster 1954 and professional judgment). 

-7- 

North slopes with 8-10 inches of effective residual grass 
cover. Shrub coulees of 45-60 percent crown cover and 6-8 
feet high. Same shrub species plus juniper. Deciduous shrubs 
with 75 percent of terminal leaders alive. More grasses and 
less forbs, still in good condition. 

-4- 

North slopes with 6-8 inches of effective residual grass 
cover. Coulees with more scattered shrubs (20-30 percent 
crown cover). Shrubs 4-6 feet tall. Two-three shrub species 
present that have 25-50 percent of terminal leaders alive. 
Understory sparsely vegetated. 

-1- 

North slopes with 3-4 inches of effective residual grass 
cover. Shrubs very scattered in coulees (less than 10 per- 
cent crown cover). One or two species less than 2 feet tall. 
Shrubs decadent with less than 25 percent of leaders alive. 


Mourning dove habitat criteria and rating values 


-10- 

Large grain or weed fields within 1 mile of deciduous shrub 
area (Edminster 1954, Moore and Pearson 1941). Shrub crown 
cover 30-60 percent in scattered clumps (professional judgment) 
Shrub areas with 4 miles of water (McClure 1943) . 

-7- 

Only road edges available for feeding. These areas are within 
1 mile of shrub areas. Shrub crown cover 10-30 percent in 
scattered clumps. These areas are up to 5 miles from water. 

-4- 

Only grassland available as seed source. These feeding areas 
are more than 2 miles from shrub areas. Shrub crown cover is 
less than 10 percent and these areas are up to 6^ miles from 
water . 


147 


Appendix 2d 


Appendix Table 2d. (Cont'd.) 

-1- No seed source. Shrub crown cover less than 5 percent in 

coulees. Water is 8+ miles away. 

Mule deer habitat criteria and rating values 

-10- Shrubby areas with shrubs 5-6 feet high in patches of 

800-1600 feet in length for hiding and fawning. (Thomas 
et al. 1976). Shrubs for winter food source include juniper, 
snowberry, rose, chokecherry, and sagebrush (Kufeld et al. 
1973, Mackie 1970). These plants have 75 percent or more 
of current year's growth retained through the winter (pro- 
fessional judgment). Forbs abundant (15 percent of the 
ground cover) (K. Hamlin personal communication, Kufeld et al. 
1973). Topographic relief in the form of cuts, ravines, 
and rolling hills (professional judgment). 

-7- Shrubby areas with shrubs 2-6 feet high in patches of 200-800 

feet in length for hiding and fawning. Shrubs for winter food 
are the same as above. These plants retain 50-75 percent of 
current year's growth through the winter. Forbs 10 percent 
of the ground cover. Topographic relief is less pronounced, 
no deep cuts or ravines. 

-4- Shrubby areas less than 2 feet in height are quite scattered 

and smaller than 200 feet in length. Shrubs for winter food 
include juniper, rose and sagebrush. These species are not 
abundant and retain 25-50 percent of current year's growth 
through the winter. Forbs 5 percent of the ground cover. 

Only gently rolling hills for topographic relief. 

-1- No shrub patches large enough to provide hiding cover. Only 

sagebrush and juniper available for winter food. Few forbs 
occur. Flat to rolling sage-grasslands. 


1 = poor, 4 = fair, 7 = good and 10 = excellent 


148 


Appendix 2. (Cont'd.) 

Appendix Table 2e. Deciduous river bottom vegetative type on the 
Charles M. Russell National Wildlife Refuge, Montana. 


Raccoon habitat criteria and rating values 


-10- 

Deciduous tree stand of large, mature trees within 500 feet 
of water (professional judgment, Stuewer 1943, Giles 1942). 
Average height of trees over 55 feet (Stuewer 1943). Average 
DBH of trees, 25 inches (Stuewer 1943). Denning trees, or 
their potential, available at rate of 4+ per 15-20 acres 
(Stuewer 1943). Trees within 0.5 mile of cultivated cropland, 
if available (Caras 1967). 

-7- 

Deciduous trees stand with 20-30 percent large mature trees. 
Stand within 800 feet of water. Average height of trees 38 
feet. Average DBH of trees 18 inches. Denning trees, or 
their potential, available at rate of 2 per 15-20 acres. 
Trees 1.25 miles from cultivated cropland, if available. 

-4- 

Young deciduous tree stand. Stand within 1200 feet of water. 
Average height of trees 20 feet. Average DBH of trees 10 
inches. No denning trees available but ground-den sites 
available . 

-1- 

No trees or just saplings. Over 1,600 feet from water. No 
den sites. 


White-tailed deer habitat criteria and rating values 


-10- 

River bottom with overstory of continuous large mature cotton- 
woods (Mussehl and Howell (ed.) 1971). Shrub understory 
that is dense and difficult to walk through (professional 
judgment). Palatable browse species like snowberry, choke- 
cherry, cottonwood, green rabbitbrush, serviceberry , and red 
osier dogwood present and less than 6 feet tall (Allen 1968). 
Plants retain 75 percent or more of current year's growth 
through the winter (Young and Payne 1948). Openings scattered 
through river bottom (McCaffery and Creed 1969). Coulees of 
deciduous shrubs within sight of the river bottom (profes- 
sional judgment). Include bottoms numbered 16-20 from the 
mouth of the reservoir (K. Hamlin personal communication and 
professional judgment). 

-7- 

River bottom with overstory of large mature cottonwoods that 
are not continuous. Shrub understory that is moderately dense 
and can be walked through. Three-four palatable browse species 
(as listed above) within 6 feet of ground level. Plants re- 
tain 50-75 percent of current year's growth through the 
winter . 


149 


Appendix 2e 


Appendix Table 2e. (Cont’d.) 

Occasional openings throughout the river bottom. Include 
bottoms numbered 11-15 from mouth of the reservoir. 

-4- River bottom with cottonwood overstory occurring as clumps 

of scattered trees. Light shrub understory, one-two palatable 
browse species as listed above within 6 feet of ground level. 
Plants retain 25-50 percent of current year’s growth through 
the winter. Agricultural fields adjacent to river bottom. 
Include bottoms 6-10 from mouth of the reservoir. 

-1- River bottom with no overstory, and only very scattered 

shrubs. Large proportion of annuals compose ground cover. 
Include bottoms 1-5 from mouth of the reservoir. 

Eastern kingbird habitat criteria and rating values 

-10- Mature deciduous forest contiguous to river system for perch 
sites (Manolis 1973). Understory of trees and shrubs 6-10 
feet high for nesting (Graber et al. 1974, Davis 1955). These 
areas are surrounded by open country used for feeding (Graber 
et al. 1974). 

-7- Shrubs and young trees contiguous to a stream bank. Open 

country surrounds water system. 

-4- Scattered mature deciduous trees contiguous to river system. 

Lack of shrub-small tree understory. Open country is not 
nearby. 

-1- Shrubby coulees not within site of river bottom. These coulees 

lack water. Open country is not nearby. 


150 


Appendix 2. (Coni' d.) 


Appendix Table 2f. Cultivated lands vegetative type on the 
Charles M. Russell National Wildlife Refuge, Montana. 


American kestrel habitat criteria and rating values 


-10- 

Agricultural fields adjacent to cottonwood river bottoms 
(Eyre and Paul 1973) . Cottonwoods should be mature with 
cavities for nesting (Olendorff 1973). Suitable perch sites 
available. This could include fence posts, power lines, 
rocks, or boulders (Roest 1957). 

-7- 

Agricultural fields adjacent to coulees with ash or cottonwood 
trees. Trees are mature but not of cavity-bearing size. 

Perch sites are also more restricted. 

-4- 

Agricultural fields on upland sites adjacent to grasslands 
and/or ponderosa pine trees without suitable nest sites. Few 
suitable perch sites occur. 

-1- 

Extensive, rolling grassland. No trees or rock outcrops for 
nesting or perching. 


Mourning dove habitat criteria and rating values 


-10- 

Cultivated fields within 1 mile of coulees containing 
deciduous shrubs and/or river bottoms (Edminster 1954, Moore 
and Pearson 1941) . Shrubby coulees and river bottom forest 
should be semi-open (30-60 percent canopy cover) (profes- 
sional judgment). Distance to water is 4 miles or less 
(McClure 1943). 

-7- 

Cultivated fields within 1 mile of sage-grassland or deciduous 
shrub coulees. Shrub crown cover is 10-30 percent. Water is 
up to 5 miles away. 

-4- 

Cultivated fields more than 2 miles from sage-grassland or 
deciduous shrub coulees. Shrub coulees are quite scattered, 
and shrub crown cover is less than 10 percent. Water is up 
to 6^2 miles away. 

-1- 

No cultivated fields. Only very scattered shrubs or trees. 
Water is 8 miles or more away. 


1 = poor, 4 = fair, 7 = good and 10 = excellent 


151 


Appendix 2g. 


Appendix 2. (Cont’d.) 

Appendix Table 2g. Ponds (evaluated in whatever vegetative type it 
occurred in) on the Charles M. Russell National Wildlife Refuge, Montana. 


Muskrat habitat criteria and rating values 

-10- Water level stable throughout the year (Errington 1948, 1963). 
Water gradually increasing to a maximum depth of 4 feet 
(Sather 1958, Errington 1948). Emergent vegetation (partic- 
ularly cattail and bulrush) growing over 1/2 of surface area 
in a scattered pattern (Errington 1963) . Shoreline beyond 
emergent vegetation completely stable and vegetation 12 inches 
high (Errington 1963, inference and professional judgment). 

-7- Water level fluctuations annual and of one foot or less. 

Water depth gradually increasing to a maximum of three feet. 
Emergent vegetation growing on half of the area of just along 
shoreline. Shoreline stable and in good condition but vege- 
tation short (6-12 inches high) . 

-4- Water level fluctuations frequent throughout the year and of 

more than one foot. Water depth 1-2 feet. Emergent vegeta- 
tion covers 25 percent or less of the surface. Shoreline 
damaged and/or vegetation very short (less than 6 inches 
high) . 

-1- Water level fluctuation extreme (over 5 feet), resulting in 

dry and flood conditions which either exposes or inundates 
lodges and dens or water depth of pond less than 1 foot. No 
emergent vegetation. Shoreline only bare ground with no 
tat ion. 

General waterfowl habitat criteria and rating values 

-10- Pond is at least 5 acres (526 feet in diameter) at low water 
in late summer (Crissey 1968). Submerged aquatic vegetation 
covers entire bottom of pond (professional judgment). Emer- 
gent vegetation (bulrush and cattail) cover 1/2 surface area 
of pond in a scattered pattern (professional judgment). 
Herbaceous upland vegetation, including brush if present, 
within 150 feet of the pond is 1.5+ feet tall and 75+ percent 
ground cover (Bent 1923, Bennet 1938, Burgess et al. 1965, 
Drewien and Springer 1969). Pond contains at least one island 
for goose nesting (Geis 1956, Sherwood 1968, Pakulak 1969). 

-7- Pond is 3.5 acres (440 feet in diameter) at low water in late 

summer. Submerged aquatic vegetation covers 75 percent of 
bottom. Emergent vegetation covers 1/2 surface area of pond 
in mostly a block or band. Herbaceous /brushy upland vegeta- 
tion is 1 foot tall and has 60 percent ground cover. Only 
muskrat houses available for goose nesting. 


152 


Appendix Table 2g. (Cont'd) 

-4- Pond is 2 acres (332 feet in diameter) at low water in late 

summer. Submerged aquatic vegetation covers 25 percent of 
bottom. Emergent vegetation is only around 1/2 of the pond 
edge. Herbaceous/brush upland vegetation is 6-12 inches tall 
and has 30 percent ground cover. Peninsula of land for goose 
nesting . 

-1- Pond dries up every summer. Little or no submerged aquatic 

vegetation present. No emergent vegetation present. Upland 
vegetation is mostly herbaceous of less than 3 inches height 
and the shoreline area is bare ground. Only shoreline avail- 
able for goose nesting. 


1 = poor, 4 = fair, 7 = good and 10 = excellent 


153 


Appendix 2h 


Appendix 2. (Cont'd.) 

Appendix Table 2h. Wildlife habitat ratings by major habitat type on 
Charles M. Russell National Wildlife Refuge, Montana. 


Individual 


Vegetative type, wildlife 

criteria 

Overal 1 

species and criteria 

rating 

rating 


Sage-greasewood -grass land 


Sage grouse 


4.2 

canopy cover of sage 

4.3 


sage height 

6.4 


canopy cover of forbs 

5.0 


distance to water 

8.7 


alfalfa fields 

3.8 


Golden eagle 


5.5 

tract size 

9.0 


suitable perch/nest sites 

5.3 


cover for rodent population 

5.3 


human disturbance 

7.7 


Pronghorn 


5.1 

mixture of shrubs & grass 

4.7 


forb availability 

5.6 


silver sage availability 

4.6 


sage canopy cover 

5.1 


sage height 

7.5 


topography 

7.2 


Mule deer 


4.7 

winter browse 

4.9 


condition of browse 

5.5 


forb-summer & fall 

5.7 


other shrubs 

4.9 


topography relief 

6.3 


Ponderosa pine-juniper 

Red-tailed hawk 


6.0 

forest canopy cover 

8.7 


adjacent sage /grassland 

9.0 


tree size-nesting/perching 

7.7 


cover for prey 

4.9 


Elk 


6.0 

coulee availability 

6.5 


juniper cover 

6.7 


topography 

7.8 


feeding sites 

5.5 


water availability 

8.3 



154 


Appendix Table 2h. (Cont'd.) 


Sharp-tailed grouse 


4.5 

north slope residual cover 

3.8 


shrub crown cover 

4.1 


shrubby coulees 

3.9 


understory quality 

5.2 


Porcupine 


6.2 

forest canopy cover 

8.6 


tree size 

8.3 


ground cover 

5.7 


denning sites 

6.2 


Mountain bluebird 


6.0 

forest canopy cover 

8.8 


nesting cavities 

5.3 


ground cover height 

7.5 


Bobcat 


5.0 

forest canopy cover 

5.6 


understory density 

4.9 


rock outcrops and ledges 

2.5 


coulee cover 

4.9 


Mule deer 


5.5 

interspers ion-pine/ sage /grass 

5.5 


summer/fall food-forbs and shrubs 

5.1 


winter food-shrubs 

5.5 


•assland-deciduous shrub 

Sharp-tailed grouse 


5.6 

height of shrubs 

6.0 


north slope residual cover 

4.9 


shrub crown cover 

5.0 


shrubby coulees species 

7.0 


grass/ forbs 

7.6 


Mourning dove 


5.4 

seed source availability 

5.2 


shrub crown cover 

6.2 


distance to water 

9.9 


Mule deer 


6.1 

shrub height 

8.6 


shrub patch size 

4.4 


winter browse species 

6.8 


forb abundance 

5.6 


topography 

6.8 



155 


Appendix 2h 


Appendix Table 2h. (Cont'd.) 

Riparian, deciduous riverbottom-Missouri River 

Raccoon 


7.2 

distance of trees to water 

8.3 


height and DBH of trees 

7.6 


denning tree availability 

7.4 


distance to cropland 

6.9 


White-tailed deer 


6.2 

overstory density 

7.8 


understory density 

6.2 


browse availability 

5.4 


availability of openings 

7.0 


Eastern kingbird 


8.1 

tree size and density 

8.9 


understory 

6.9 


availability of open country 

9.6 


Riparian, deciduous, r iverbottom-other streams 

Raccoon 


6.6 

distance of trees to water 

7.2 


height and DBH of trees 

7.2 


denning tree availability 

7.4 


distance to cropland 

7.8 


White-tailed deer 


4.2 

overstory density 

5.5 


understory density 

4.0 


browse availability 

3.4 


availability of openings 

7.5 


Eastern kingbird 


6.5 

tree size and density 

7.0 


understory 

5.6 


availability of open country 

10.0 


Cultivated lands 

American kestrel 


6.5 

adjacent land type 

6.8 


nesting cavity availability 

6.0 


perch availability 

7.8 



156 


Appendix Table 2h . (Cont'd.) 


Mourning dove 

distance to interspersed land 7.9 

canopy cover-forest or shrub 6.6 

distance to water 10.0 

Ponds 

Muskrat 

water stability 6.8 

water depth 7.5 

emergent vegetation abundance 3.2 

shoreline stability and vegetation 4.6 

Waterfowl 

pond size 3.9 

submerged aquatic vegetation 3.2 

emergent vegetation 3.0 

upland vegetation 3.8 

goose nesting sites 3.8 


0.0-2. 5 = poor, 2. 6-5.0 = fair, 5. 1-7.5 = good and 7.6-10.0 


7.3 


4.0 


3.4 


= excellent 


157 


Appendix 3 


Appendix 3. Memorandum of agreement between District Engineer, Omaha 
District, Corps of Engineers, and Area Manager, Billings Area Office, 
Fish and Wildlife Service, for the Charles M. Russell National Wildlife 
Refuge and Fort Peck Lake Project, Montana. 

The U.S. Fish and Wildlife Service and the U.S. Army Corps of 
Engineers recognize the National, Regional, and Local importance of the 
natural resources contained within the Charles M. Russell National 
Wildlife Refuge and the Fort Peck Lake Project, Montana, hereinafter 
called the Area. Both agencies also recognize the public interest can 
be best served through coordinated planning and management efforts to 
maximize opportunities for conserving these resources and minimize the 
adverse impacts associated with the management actions of the respective 
agencies . 

The parties to this Memorandum of Agreement agree to coordinate, 
cooperate, and, when appropriate, jointly develop resource management 
plans and other actions. 

The Omaha District Engineer of the Corps of Engineers and the 
Billings Area Manager*of the Fish and Wildlife Service will develop 
mechanisms necessary to insure that implementation of all actions are in 
consonance with agreements contained herein. 

In each phase of planning and future management and in the formula- 
tion of proposals for the preservation, conservation, management, and/or 
development of the natural resources within the Area, both agencies will 
consult and identify potential actions which could have adverse or bene- 
ficial impacts on the executive and legislative mandated responsibili- 
ties of each agency. Both agencies agree to coordinate efforts at the 
field operating level to resolve these potential areas of conflict and 
to modify the potential actions to the extent permitted by each agency’s 
policies and regulations, and applicable laws. 

It is further recognized by both agencies that the natural re- 
sources in the Area should be made available for public enjoyment and 
appropriate recreation provided that public use and associated devel- 
opments do not adversely affect fish and wildlife and their habitats and 
will be operated in a generally natural setting compatible with the 
Missouri River Breaks Ecosystem. 


Date 17 July 1979 


Date 11 July 1979 


(signed) V. D. Stipo 
V. D. Stipo 

Col., Corps of Engineers 
Omaha District Engineer 

(signed) Wally Steucke 
Wally Steucke 
Area Manager * 

Billings Area Office 

U. S. Fish and Wildlife Service 


* The Billings Area Manager position no longer exists. Functions of that 
office are now under the Regional Office of U.S. Fish and Wildlife Service 
in Denver, Colorado. 


158 


Appendix 4. Executive Order 7509 establishing the Fort Peck Game Range, 
Montana. 

By virtue of and pursuant to the authority vested in me as President 
of the United States and by the act of June 25, 1910, ch . 421, 36 Stat. 
847, as amended by the act of August 24, 1912, ch. 369, 37 Stat. 497, 
and subject to the conditions therein expressed and to all valid exist- 
ing rights, it is ordered that the following-described lands, insofar as 
title thereto is in the United States, be, and they are hereby, withdrawn 
from settlement, location, sale, or entry and reserved and set apart for 
the conservation and development of natural wildlife resources and for 
the protection and improvement of public grazing lands and natural 
forage resources: Provided, That nothing herein contained shall restrict 

prospecting, locating, developing, mining, entering, leasing, or patent- 
ing the mineral resources of the lands under the applicable laws: 

Provided further, that any lands within the described area which are 
otherwise withdrawn or reserved will be affected hereby only insofar as 
may be consistent with the uses and purposes for which such prior with- 
drawal or reservation was made: And provided further, That upon the 

termination of any private right to, or appropriation of, any public 
lands within the exterior limits of the area included in this order, or 
upon the revocation of prior withdrawals unless expressly otherwise 
provided in the order of revocation, the lands involved shall become 
part of this preserve: 

(Legal Description available in FWS office Lewistown, Montana.) 

This range or preserve, insofar as it relates to conservation and 
development of wildlife, shall be under the joint jurisdiction of the 
Secretaries of the Interior and Agriculture, and they shall have power 
jointly to make such rules and regulations for its protection, adminis- 
tration, regulation, and improvement, and for the removal and disposition 
of surplus game animals, as they may deem necessary to accomplish its 
purposes, and the range or preserve, being within grazing districts duly 
established pursuant to the provisions of the act of June 28, 1934, ch . 
865, 48 Stat. 1269, as amended by the act of June 26, 1936, Public No. 
827, 74th Congress, shall be under the exclusive jurisdiction of the 
Secretary of the Interior, so far as it relates to the public grazing 
lands and natural forage resources thereof: Provided, however, That the 

natural forage resources therein shall be first utilized for the purpose 
of sustaining in a healthy condition a maximum of four hundred thousand 
(400,000) sharp-tailed grouse, and one thousand five hundred (1,500) 
antelope, the primary species, and such nonpredatory secondary species 
in such numbers as may be necessary to maintain a balanced wildlife 
population, but in no case shall the consumption of forage by the com- 
bined population of the wildlife species be allowed to increase the 
burden of the range dedicated to the primary species: Provided further. 

That all the forage resources within this range or preserve shall be 
available, except as herein otherwise provided with respect to wildlife, 
for domestic livestock under rules and regulations promulgated by the 


159 


Appendix 4 


Appendix 4. (Cont'd.) 

Secretary of the Interior under the authority of the aforesaid act of 
June 28, 1934, as amended: And provided further that Land within the 

exterior limits of the area herein described, acquired, and to be ac- 
quired by the United States for the use of the Department of Agriculture 
for conservation of migratory birds and other wildlife, shall be and 
remain under the exclusive administration of the Secretary of Agricul- 
ture and may be utilized for public grazing purposes only to such extent 
as may be determined by the Said Secretary to be compatible with the 
utilization of said lands for the purposes for which they were acquired 
as aforesaid under regulations prescribed by him. 

The reservation made by this order supersedes as to the above- 
described lands the temporary withdrawal for classification and other 
purposes made by Executive Order No. 6910 of November 26, 1934, as 
amended . 

This preserve shall be known as the Fort Peck Game Range. 


Franklin D. Roosevelt 


The White House, 

December 11, 1936. 

(No. 7509) 

(F.R. Doc. 3825-Filed, December 14, 1936; 2:30 p.m.) 


160 


Appendix 5. Federal stocking levels In AUMs under each management alternative (livestock) for the Charles M. Russell National Wildlife 
Refuge, Montana. 


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163 


Appendix 6 


Appendix 6. Public Law 94-223 94th Congress, H.R. 5512, February 27, 
1976. 


AN ACT 

To amend the National Wildlife Refuge System Administra- 
tion Act of 1966, and for other purposes. 

Be it enacted by the Senate and House of Represen- 
tatives of the United States of America in Congress as- 
sembled, That subsection (a) of section 4 of the National 
Wildlife Refuge System Administration Act of 1966 (16 
U.S.C. 668dd (a) is amended to read as follows: 

"(a) (1) For the purpose of consolidating the authori- 
ties relating to the various categories of areas that are 
administered by the Secretary of the Interior for the con- 
servation of fish and wildlife, including species that 
are threatened with extinction, all lands, waters, and 
interests therein administered by the Secretary as wild- 
life refuges, areas for the protection and conservation 
of fish and wildlife that are threatened with extinction, 
wildlife ranges, game ranges, wildlife management areas, 
or waterfowl production areas are hereby designated as 
the 'National Wildlife Refuge System' (referred to herein 
as the 'System'), which shall be subject to the provisions 
of this section, and shall be administered by the Secre- 
tary through the United States Fish and Wildlife Service. 
With respect to refuge lands in the State of Alaska, those 
programs relating to the management of resources for which 
any other agency of the Federal Government exercises ad- 
ministrative responsibility through cooperative agreement 
shall remain in effect, subject to the direct supervision 
of the United States Fish and Wildlife Service, as long as 
such agency agrees to exercise such responsibility. 

"(2) No acquired lands which are or become a part of 
the System may be transferred or otherwise disposed of 
under any provision of law (except by exchange pursuant 
to subsection (b)(3) of this section) unless — 

"(A) the Secretary of the Interior determines 
with the approval of the Migratory Bird Conserva- 
tion Commission that such lands are no longer needed 
for the purposes for which the System was established; 
and 

"(B) such lands are transferred or otherwise dis- 
posed of for an amount not less than — 

"(i) the acquisition costs of such lands, in 
the case of lands of the System which were pur- 
chased by the United States with funds from the 
migratory bird conservation fund, or fair market 
value, whichever is greater; or 

"(ii) the fair market value of such lands (as 
determined by the Secretary as of the date of the 
transfer or disposal) , in the case of lands of the 
System which were donated to the System. 


National 
Wildlife 
Refuge System 
Administration 
Act of 1966, 
amendments . 
"National 
Wildlife Refuge 
System. " 


Transfer or 
disposal of 
lands , 

restriction. 


164 


Appendix 6. (Cont’d.) 
Pub. Law 94-223 


February 27, 1976 


The Secretary shall pay into the migratory bird conserva- 
tion fund the aggregate amount of the proceeds of any 
transfer or disposal referred to in the preceding sentence. 

"(3) Each area which is included within the System on 
January 1, 1975, or thereafter, and which was or is — 

M (A) designated as an area within such System by 
law. Executive order, or secretarial order; or 

"(B) so included by public land withdrawal, dona- 
tion, purchase, exchange, or pursuant to a cooperative 
agreement with any State or local government, any 
Federal department or agency, or any other govern- 
mental entity, shall continue to be a part of the 
System until otherwise specified by Act of Congress, 
except that nothing in this paragraph shall be con- 
strued as precluding — 

"(i) the transfer or disposal of acquired lands 
within any such area pursuant to paragraph (2) of 
this subsection; 

"(ii) the exchange of lands within any such area 
pursuant to subsection (b)(3) of this section; or 
"(iii) the disposal of any lands within any such 
area pursuant to the terms of any cooperative agree- 
ment referred to in subparagraph (B) of this para- 
gr aph. " 

Approved February 27, 1976. 


LEGISLATIVE HISTORY : 

HOUSE REPORT No. 94-334 (Comm, on Merchant Marine and Fisheries). 
SENATE REPORT No. 94-593 (Comm, on Commerce). 

CONGRESSIONAL RECORD: 

Vol. 121 (1975): Nov. 14, considered and passed House. 

Vol . 122 (1976): Feb. 4, considered and passed Senate, 

amended . 

Feb. 17, House concurred in Senate 

amendment . 


165 


Appendix 7 


Appendix 7. Soils limitations and capability classes, Charles M. Russell 
National Wildlife Refuge, Montana. 

Soil limitations 


The following soil mapping units on the refuge should not be grazed 
(W. Larsen personal communication): 

13 Badlands 
24E Dilts Clay 
48 Rock Outcrop 
50 Shale Outcrop 
77 Beach Sand 
88 Riverwash 

195F Cabbart-Rock Outcrop complex, 15-90 percent slopes 
241 Dilts-Badlands complex, 15-45 percent slopes 
243 Dilts-Shale Outcrop complex, 4-45 percent slopes 
249E Neldore (saline phase)-Dilts-Shale Outcrop complex, 

15-45 percent slopes 

505F Shale Outcrop-Neldore (saline phase) complex, 15-45 
percent slopes 

507F Shale Outcrop-Dilts complex, 45-60 percent slopes 

In addition, those mapping unit complexes having badlands, rock 
outcrop, or shale outcrop included were recognized as having limitations 
in that no forage allocations should be allotted to the badlands, rock 
outcrop, or shale portions (Appendix Table 7a). It was recognized that 
those complexes containing rock outcrop or shale outcrop could provide 
limited grazing on the remainder of the mapping unit. No AUMs for wild- 
life or livestock were calculated for the following: rock outcrop, 

shale outcrop, beach sand, riverwash, and portions of those complexes 
containing one of the above as a component. A shortened time frame for 
completion of the EIS did not allow for examination and elimination of 
all mapping units listed in Appendix Table 7a. Most notable of the 
omitted mapping units are others including the Dilts series, a commonly 
represented soil complex component on the refuge. 

The problem of soils limitations for grazing was analyzed and re- 
solved in the following manner: it was recognized that certain soils 

should support no livestock grazing; however, it would be impractical 
and costly to fence these individual areas to prevent livestock use. 
Exclusion of an entire area from use because of soils limitations on 
only a portion of the area is not feasible. A practical way to solve 
the problem would be to recognize that soils limitations do exist, that 
it is nearly impossible to deny livestock use or wildlife use but that 
overall stocking rates should be adjusted accordingly. 


166 


Appendix 7. (Cont'd.) 
Soil capability classes 


Capability grouping shows, in a general way, suitability of soils 
for most land uses. Groups are made according to limitations of the 
soils when used for field crops, risk of damage when they are used, 
and the way they respond to treatment. The grouping does not take into 
account major and generally expensive land forming that would change 
slope, depth, or other characteristics of the soils nor possible but 
unlikely major reclamation projects and does not apply to rice, cran- 
berries, horticultural crops, or other crops requiring special manage- 
ment . 

Those familiar with the capability classification can infer from it 
much about the behavior of soils when used for other purposes, but this 
classification is not a substitute for interpretations designed to show 
suitability and limitations of groups of soils for range, forest trees, 
or engineering. 

In the capability system, all soils are grouped at three levels: 
capability class, subclass, and unit. In this report, only the first 
two levels are given for each mapping unit, since soils on CMR are not 
generally used for crops. 

Capability classes, the broadest groups, are designated by Roman 
numerals I through VIII. The numerals indicate progressively greater 
limitations and narrower choices for practical use, defined as follows: 

Class I- few limitations restricting use. 

Class II- moderate limitations that reduce choice of plants or that 
require moderate conservation practices. 

Class Ill- severe limitations that reduce choice of plants, require 
special conservation practices or both. 

Class IV- very severe limitations that reduce choice of plants, 
require very careful management or both. 

Class V- not likely to erode but have other limitations, impractical 
to remove, that limit use largely to pasture, range, woodland, or wild- 
life . 


Class Vi- severe limitations that make them generally unsuited to 
cultivation and limit use largely to pasture, range, woodland, or wild- 
life . 


Class Vll- very severe limitations that make them unsuited to cul- 
tivation and that restrict use largely to pasture, range, woodland, 
or wildlife. 

Class VUI-limitations that preclude use for commercial plants and 
restrict use to recreation, wildlife, water supply, or esthetic purposes. 


167 


Appendix 7 


Appendix 7. (Coni' d.) 

Capability subclasses are soil groups within one class; they are 
designated by adding a small letter, e , w, _s , or _c to the class numeral, 
for example, lie. The letter _e shows that the main limitation is risk 
of erosion unless close-growing plant cover is maintained, w shows that 
water in or on the soil interferes with plant growth or cultivation (in 
some soils the wetness can be partly corrected by artificial drainage), 

_s shows that the soil is limited mainly because it is shallow, salty, 
droughty, or stony, and _c , used in only some parts of the United States, 
shows that the chief limitation is climate that is too cold or dry. 

In Class I, there are no subclasses because soils of this class 
have few limitations. Class V can contain, at most, only subclasses 
indicated by w, _s and c_ because soils in Class V are subject to little 
or no erosion, though they have other limitations that restrict use 
largely to pasture, range, woodland, wildlife, or recreation. 


168 


Appendix Table 7 a. Soils mapping units having grazing limitations on the Charles M. Russell National Wildlife 
Refuge, Montana. 

— Mapping ' ' ' 

Mapping unit unit Approximate acreage by county 

name number Valley Fergus McCone Petroleum Phillips Garfield Total 


m on 

CN 

as 

00 

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NO 

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169 


Neldore-Di Its- Shale 
Outcrop complex, 

8-60% slopes 386F 5132 14,649 690 20,471 

Neldore-Shale Outcrop- 


Appendix 7a 


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170 


Appendix 8. Range survey methodology and productivity, Charles M. 
Russell National Wildlife Refuge, Montana. 

METHODOLOGY 


A range site and condition survey was conducted on CMR in 1978 by 
four range specialists. The survey was in accordance with the 1976 SCS 
National Range Handbook. 

Soils mapping was done prior to the range survey in accordance with 
standard soil survey procedures. Mapping procedures consisted of iden- 
tifying known soil series or complexes and mapping these units on 
1:24000 aerial photographs. Once the soils mapping was completed for a 
given area, range/soils specialists devised a correlation key for map- 
ping range sites on the basis of soils units. Range site mapping units 
are based upon soils mapping units but are expressed in terms of general 
soils features, instead of series names and slope gradients used in 
standard soil survey procedures. For example, a soil identified as an 
Absher clay loam, 0-4 percent slopes in the soil survey would be con- 
sidered a dense clay range site for purposes of range survey procedures. 
This key, which contains all range site/soils mapping units present on 
the refuge, is on file in the refuge headquarters in Lewistown. 

Range sites and condition classes for all lands within the refuge 
above the high water mark of Fort Peck Reservoir, 2,250 feet msl, were 
mapped on 1:24000 scale aerial photographs. The range sites were then 
tallied by site and condition class acreages for all sections within the 
refuge by FWS . These range site summaries are also on file in Lewistown. 
Following the acreage tabulations, each section was assigned to a pre- 
cipitation zone and geographic location, and initial stocking rates were 
tabulated in terms of total AUMs/section in accordance with the SCS 
Montana Grazing Guides. This stocking rate is based upon the amount of 
forage that can be taken during normal or average years and still main- 
tain or improve the range condition. Recommended stocking rates are 
obtained by examining the soil's properties, which are fundamental to 
this inventory system and the basis for naming a given range site and 
upon geographic and topographic features and climate (precipitation). 

The recommended stocking rates assume that reasonably uniform grazing 
will occur over the entire area. Stocking rate cuts for inaccessibility 
because of topography or lack of water are not provided in the SCS 
Montana Grazing Guides and are left to the planner's or manager's know- 
ledge of the area for final stocking rate appropriations (Appendix 15). 

Clipping studies on pristine sites resulted in information which 
lends insight to the productivity of these sites at climax and the 
percent weight composition by species in the climax community. Nor- 
mally, productivity of different sites is expressed in terms of annual 
production by air dry weight in favorable years, unfavorable years, 
and long-term average for sites rated as excellent condition. Com- 
parison of the present range situation expressed as a percentage of the 
potential at climax provides the observer with an ecological site condi- 
tion rating. 


171 


Appendix 8 


Appendix 8. (Cont'd.) 

Appendix Table 8a summarizes expected annual site productivity for 
range sites commonly found on the wildlife refuge. Data presented are 
taken from SCS range guides and technical guides and are presented only 
as general figures for those sites. The information does provide in- 
sight as to how soils limitations such as depth, texture, and salinity 
problems affect vegetative productivity. Additional information re- 
garding site productivity has been collected by Prodgers in response to 
differences in precipitation (Appendix Table 8b) . 

Criticisms concerning this survey were particularly directed 
toward the fact that 1978 was an abnormally high moisture year. Vege- 
tative production was much greater than normal on the refuge. Critics 
of the survey indicated that perhaps this biased the range condition 
upward and provided a distortion that range conditions were better than 
the actual situation. 

It should be stated that range condition determined by SCS methods 
is based upon percent by weight of the current year's growth (actual 
air-dry measurements or estimates) of each species in the community and 
the percent that should be present in a climax situation. The high 
moisture year of 1978 would have provided as realistic a situation as 
one of drought; annual weeds would normally not grow at all during an 
exceptionally dry year, whereas they would be abundant in wet years. 
Perennial grasses, forbs, and shrubs would be less affected because of 
better adapted root systems. Rates of vegetative production in per- 
ennial species would be less likely to show the extreme fluctuations 
shown by annuals during years of high or low rainfall. 

Through the summer, periodic clipping evaluations were made to 
verify range survey results. No major discrepancies were found. 

RANGE SITES AND CONDITION 


There are many differences in soils and climate of the survey area. 
For these reasons, there are several different kinds of rangeland. 

These different kinds of rangeland are called range sites. The best 
adapted group of plants is called the potential or climax community for 
the site. The climax plant community for a site varies slightly from 
year to year, but the kinds and percentage of plant composition remain 
about the same if undisturbed. Each range site has the ability to 
produce a different kind and/or amount of climax vegetation than any 
other range site. 

The original or climax combination of plants fitted the soil and 
climate of the site so perfectly that other kinds of plants could not 
move in unless the area was disturbed. So consistent is the relation- 
ship between plants, climate, and soil, that the climax plant community 
can be predicted even on severely disturbed sites if the soil is iden- 
tified. 

Range conservationists and soil scientists, working together, group 
soils which naturally grow the same climax plant communities into range 
sites . 


172 


Appendix 8. (Cont'd.) 

Repeated overuse by grazing animals, excessive burning, or plowing 
result in changes in the kinds, proportions, or amounts of climax plants 
in the plant community. Depending on the kind and degree of distur- 
bance, some kinds of plants increase while others decrease. If distur- 
bance is severe, plants which do not belong in the climax plant com- 
munity may invade. Plant response to grazing use depends on the kind of 
grazing animal, season of use, and how closely the plant is grazed. 

Under good management, near-climax plant communities can be maintained 
or, in the case of disturbed vegetation, the climax plant community will 
be gradually re-established unless the soils have been seriously eroded. 

Plants are categorized into decreasers, increasers, or invaders 
according to their response to grazing pressures. 

Decreasers are climax dominant plants that tend to decrease in 
relative amounts under close grazing. They are generally the most 
productive and most palatable to grazing animals. 

Increasers are plants in the climax vegetation that increase in 
relative amounts as the more desirable decreaser plants are reduced by 
close grazing. They are generally less palatable, woody, spinyy or so 
short they escape close grazing. 

Invaders are weedy type plants or exotics that cannot stand the 
competition of climax vegetation. They fill the void if the climax' 
plants are diminished or eliminated by disturbance. 

Range condition is an expression of the present kind of vegetation 
in relation to the climax plant community for that site. The more 
nearly the present kinds and amounts of plants are like the climax plant 
community, the higher the range condition. 

A range is in excellent condition if 76-100 percent of the vege- 
tation is of the same kinds as the climax stand. It is in good con- 
dition if the percentage is 51-75. It is in fair condition if the per- 
centage is 26-50, and in poor condition if the percentage is less than 
25. 

The present range condition provides an index to changes which have 
taken place in the plant community. More importantly, however, range 
condition is a basis for predicting the kinds and amounts of changes in 
the present plant community which can be expected from management and 
treatment measures. 

Thus, the range condition rating indicates the nature of the 
present plant community, and the climax plant cover for the range site 
represents a goal toward which rangeland management may be directed. 

Knowledge of climax plant communities of range sites and the 
nature of present plant communities in relation to that potential is 
important in planning and applying conservation on rangeland. Such 
information is the basis for selecting management objectives, design of 
grazing systems, managing for wildlife, determining potential for 
recreation, and for rating watershed conditions. 

Any management objective on rangeland must provide for a plant 
cover which will adequately protect or improve the soil and water 
resources and meet the needs of the operator. This usually involves 


173 


Appendix 8 


Appendix 8. (Cont'd.) 

increasing desirable plants and restoring the plant community to near 
climax conditions. Sometimes, however, a plant cover somewhat below 
climax will better fit specific grazing needs or wildlife habitat while 
still protecting soil and water resources. 

All range sites respond favorably to proper grazing use and systems 
of grazing deferments. 


LEGEND FOR RANGE SITES 

Range sites are kinds of rangeland that differ from each other in 
their ability to produce a significantly different kind or amount of 
climax or original vegetation. Only natural grasslands are classified 
as range sites. To fully designate a range site, a soil-group name is 
combined with the precipitation (pz) zone and geographic location; e.g. 
sandy 10-14" pz; glaciated plains, Montana. 

The following range soil-groups are listed in presumed order of 
natural productivity, considering total air-dry weight of all herbage 
produced through the entire year by all seed plants/unit of area, in 
ordinary years under climax plant cover. 

Range site descriptions: 

I. Soil groups that can produce more herbage than ordinary range 
upland because of plainly superior soil moisture availability. 

WL - wet land : lands where seepage, ponding, etc., raise the water 

table to above the surface during only a part of the growing season. 
Too wet for cultivated crops but too dry for common reed, cattails, 
or true aquatics. 

Sb - subirrigated : lands with an effective subsurface ground water 

table and water rarely over the surface during the growing season. 

SL - saline lowland : subirrigated and overflow lands where salt 

and/or alkali accumulations are apparent and salt tolerant plants 
occur over a major part of the area. 

Ov - overflow : areas regularly receiving more than normal soil 

moisture because of run-in or stream overflow. 

II. Soil groups with no obvious soil or moisture limiting factors. 

The vegetation can make a normal response to climate. 

Sa - sands : sands and loamy sands more than 20 inches deep. 

Sy - sandy : coarse to fine sandy loams more than 20 inches deep. 

Si - silty : soils more than 20 inches deep of very fine sandy 

loam, loam or silt loam. This includes soils with 2 inches or more 
of silt loam over clayey subsoils. 


174 


Appendix 8. (Cont'd.) 


Cy - clayey : granular clay loam, silty clay loam, silty clay, 

sandy clay, or clay more than 20 inches deep. 

III. Soil groups with characteristics or topographic features that limit 
moisture-holding capacity or affect infiltration rates. 

TH - thin hilly : loamy or clayey soils on steep or hilly 

landscapes with a thin A horizon and weak or no structure in 
the Subsoil but with significant root penetration deeper than 20 
inches; usually calcareous but contain less than 15 percent cal- 
cium carbonate. 

St - stony : soils more than 20 inches deep with cobbles or stones 

occupying 40-80 percent of the surface. 

Ly - limy : soils more than 20 inches deep that are nearly white 

and very limy (15 percent or more calcium carbonate) within 4 
inches of the surface. 

SwC - shallow clay : shallow granular clay soils that are 10-20 

inches deep to underlying shale or nearly impervious clays. 

SwG - shallow to gravel : soils that are 10-20 inches deep to sandy 

gravel. Few roots penetrate deeper than 20 inches. 

Sw - shal low : soils 10-20 inches deep to hard rock or softbeds of 

decomposed granite, siltstone, or sandstone; few roots penetrate 
deeper than 20 inches. 

Ps - panspo ts : areas of silty, clayey, or sandy soils in complex 

with shallow depressions of hard clays or other nearly impervious 
materials at or near the surface. The shallow depressions occupy 
20-50 percent of the site. 

DC - dense clay : relatively impervious deep nongranular clays - 

may be overlain by thin ineffectual layers of other materials; the 
dispersed layer is very hard to extremely hard when dry and very 
sticky when wet. 

TB - thin breaks : mixed soils of various depths with hard rock or 

other resistant bed outcroppings at different levels on steep 
irregular slopes; trees may occur locally above outcrops. 

Gr - gr ave 1 : coarse textured soils with more than 50 percent 

gravel and cobbles underlain by loose sand and gravel at less than 
20 inches. 


175 


Appendix 8 


Appendix 8. (Cont'd.) 

VS - very shallow : areas where few roots can penetrate deeper than 

10 inches. Outcropping of gravel or bedrock is characteristic; 
joints in bedrock may develop deep soil pockets usually marked by 
tall grasses, shrubs, or stunted trees. 

SU - saline upland : soils more than 20 inches deep with salt 

and/or alkali accumulations; salt tolerant plants occur over a 
major part of the area. 

Sh - shale : readily puddled uplands where some unweathered angular 

raw shale fragments are exposed at the surface and little, if any, 
soil profile development is evident. 

B1 - bad lands : nearly barren lands broken by drainages inter- 

mingled with small grazable areas. 


176 


Appendix 8. (Cont'd.) 

Appendix Table 8a. Site productivity of selected ran^e sites on the 
Charles M. Russell National Wildlife Refuge, Montana. 


Range site 

High 

favorable 

years 

( lbs . / acre) 

Low 

unfavorable 

years 

(lbs. /acre) 

Average 
( lbs . / acre) 

Overflow 

3,000 

2,000 

2,500 

Saline lowland 

3,500 

2,000 

3,000 

Sandy 

2,000 

1,000 

1,600 

Silty 

1,800 

1,000 

1,500 

Clayey 

1,800 

900 

1,300 

Thin hilly 

1,450 

850 

1,200 

Shallow clay 

1,200 

700 

1,000 

Shallow to gravel 

1,200 

700 

1,000 

Shal low 

1,100 

600 

900 

Panspots 

1,200 

700 

1,000 

Dense clay 

1,100 

600 

900 

Thin breaks 

1,100 

600 

900 

Shale 

500 

300 

400 

Saline upland 

600 

350 

500 

Badlands 

500 

300 

400 

^ 10-14 inches ppt 

weight (excellent 

zone. Expected annual 
condition site) . 

product ion. 

air dry 


177 


Appendix 8 


Appendix 8. (Cont'd.) 

Appendix Table 8b. Comparison of aerial production in 1977 and 1978 
on Upper Nelson Creek, approximately 12 mij.es east of the Charles M. 
Russell National Wildlife Refuge, Montana. 


Community 

1977 

product ion 
(lbs. /acre) 

1978 

product ion 
(lbs . /acre) 

1977:1978 

production 

Little bluestem 

748 

934 

1.25 

Silver sagebrush/ 

western wheatgrass/ 
blue grama 

712 

1,801 

2.53 

Little bluestem- 

bluebunch wheatgrass 

498 

1,025 

2.06 

Blue grama thread leaf 

sedge /need le-and -thread 

361 

1,148 

3.86 

Bluebunch wheatgrass/ 
blue grama- thread leaf 

331 

1,143 

3.45 

Need le-and -t hr ead- 

western wheatgrass/ 
blue grama 

297 

1,264 

4.25 

Need le-and-thread/blue 
grama-threadleaf sedge 

194 

1,015 

5.23 

Western wheatgrass/ 
blue grama 

180 

1,488 

8.28 

Blue grama 

176 

692 

3.93 

Blue grama/western 
wheatgrass 

14 

1,740 

122.00 


Data from R. Prodgers 1979. 


178 


Appendix 9. Range condition class breakdown by livestock operator and allotment on the Charles 
Russell National Wildlife Refuge, Montana. 


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180 


Appendix 9 


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182 


Appendix 10. Direct economic impacts of changes in livestock forage 
supplies - livestock businesses that use the Charles M. Russell National 
Wildlife Refuge. 

The purpose of this analysis is to estimate direct economic impacts 
on livestock producers from changes in forage allocations on the Charles 
M. Russell National Wildlife Refuge. Although sheep and horses use the 
refuge, cattle account for over 90 percent of the livestock grazed. A 
little over 40,000 head of cattle use the refuge to obtain an average of 
about 13 percent of their annual nutrient requirements. The grazing 
season is predominately spring-summer-fall with some winter grazing. 

Procedures 


Procedures for estimating economic impacts include 1) grouping pro- 
ducers by size of operation; 2) preparing cost and return budgets for 
each group; and 3) measuring impacts on businesses with the use of 
linear programming models. 

Producers are stratified into four groups based on estimated herd 

size : 


Size Group 

Producers 

0-99 

12 

100-199 

19 

200-299 

19 

300 and over 

37 

Total 

87 


Enterprise budgets in Appendix Tables lOa-d present costs and 
returns for each size group using 1979 as the base year. Production and 
price assumptions shown in the tables are representative for the area 
based on producer estimates and USDA published production data. Costs 
other than feed are unpublished USDA numbers taken from field surveys 
and indexed to account for inflation. Interest on operating capital 
assumes funds are in use six months at the Production Credit Associa- 
tion’s average annual interest rates. Interest on investment is based 
on Federal Land Bank rates. General Farm Overhead includes utilities, 
professional fees, organization dues, and other items not used exclu- 
sively for livestock productions. 

The analysis of impacts assumes several things: 1) that annual 

feed sources are limited to those currently available on the ranches; 2) 
that rental or purchase of pasture is not possible; and 3) that the cost 
of shipping hay into the area makes this alternative prohibitive. 
Therefore, reductions in herd size and reallocation of present feed 
supplies are considered the only mitigating actions available to pro- 
ducers . 

In the Linear Programming models, impacts are first estimated for 
each herd size group (Appendix Tables lOj-m) . Included is a wide range 
of adjustments which may occur within each group. Weighted average and 
aggregate adjustments summarized in Appendix Table lOe are derived from 


183 


Appendix 10 


Appendix 10. (Cont'd.) 

these size group analyses. Aggregate direct producer impacts shown in 
Appendix Table lOe are annual estimates which must be multiplied by 
years in the planning period to derive total project impacts. Aggregate 
impacts are measured in terms of changes in gross income, cash expendi- 
tures, return above cash costs (net income), cattle numbers, and labor 
use . 

The Linear Programming Approach generated a $12.87 per AUM value of 
the CMR forage to the CMR permittees. This value was thus utilized as 
an integral part of the Linear Programming Approach. For a discussion 
of these shadow prices or values in a Linear Programming context, see 
Betters, 1977, or any Management Science text. 

The analysis indicates that producers would incur a 3 percent 
reduction in aggregate gross income with the Proposed Action, while the 
Intensive Wildlife and No Grazing options would trigger a 6 percent and 
11 percent reduction, respectively. Change in gross income with the 
Multiple Use alternative would be small - down less than 1 percent. 
Aggregate gross income effects of the Proposed Management alternative 
seem to be relatively small. 

Aggregate net income changes or returns above cash costs are more 
pronounced for the alternative management systems. Reductions range 
from 1 percent with Multiple Use to 12 percent with No Grazing. Net 
income is the money producers use to pay family living expenses, replace 
old or worn equipment, and make mortgage payments on borrowed investment 
capital. A reduction in this variable will adversely affect producers, 
particularly those with large outstanding debts. Mortgage payments 
usually have priority in expenditures of net income. Therefore, actions 
which reduce net income will impact most heavily on dollars available 
for family use and maintenance of depreciable assests. Average annual 
dollar reductions per producer with each action are: Proposed Action, 

$3,057; Intensive Wildlife Management, $5,552; Multiple Use, $690; 
and No Grazing, $9,724. For individual producers, these values will 
vary, depending upon the size of the operation. The full implications 
of these income adjustments cannot be assessed unless information is 
available relating to producer dependency on livestock for his total 
livelihood. This kind of data is not available. But it can be assumed 
that producers who rely solely on cattle for income will be affected 
more than those with multiple enterprises or off-farm income. 

The average herd size for producers using the refuge is about 483 
cattle with a range from less than 10 to more than 4,000. Average 
reductions in herd size with the different areas are: Proposed Action, 

16 cattle; Intensive Wildlife Management, 29 cattle; Multiple Use, 

4 cattle; and No Grazing, 51 cattle. Herd reductions for individual 
producers will deviate from the average. Herd reductions will cause 
some diseconomies in the businesses through less efficient use of resources 
which will cause operating costs per cow to increase. These cost increases 
are shown on Appendix Table lOf for different reductions in refuge 
grazing. Part of the cost increases stem from loss of a low cost forage, 
while part comes from higher fixed cash costs per cow. 


184 


Appendix 10. (Cont'd.) 


Some reductions in labor use and labor efficiency are associated 
with the alternative management programs on the refuge. Aggregate labor 
needs decline as follows: Proposed Action, 6.5 man-years; Intensive 

Wildlife Management, 11.9 man-years. Multiple Use, 1.4 man-years; and No 
Grazing, 20.9 man-years. The reduction in hired labor is a direct loss 
of employment. Family labor hours represent a decrease in efficiency 
since the producer will probably continue with his livestock enterprise 
but have less work to do with his available time. 

Individual Producer Impacts 

The dicussion above has assessed average impacts for producers as a 
group. There are differences among individual refuge users which aver- 
ages cannot identify. Data limitations restrict analysis of these 
differences. However, these are two which can be considered. Herd size 
and refuge dependency to annual forage can interact to determine some 
individual impacts. A distribution of producers based on these criteria 
is shown in Appendix Table lOg. The percentages indicate that producers 
with 100-200 cows tend to be more dependent on refuge forage than either 
very small or very large herds. Some producers in all size groups have 
high dependencies. There are three small herds with over 50 percent 
dependency. However, these each have fewer than 11 cattle, so impacts 
on proposed adjustments in forage will be small. In the 100-199 cattle 
group, one producer is 74 percent dependent, and three producers are 31- 
50 percent dependent on the refuge. Similiarly, the 200-299 cattle 
group includes one producer 60 percent dependent, and two producers 31- 
50 percent dependent. Among herds of 300 or more cattle are four pro- 
ducers with 31-50 percent dependency. 

Impacts on high dependency producers are more severe than the 
average. Appendix Table lOf illustrates these differences for the 
Proposed Action. Average reductions in return above cash costs range 
$385 for small herds up to $4,900 for large herds. Producers with high 
dependencies will incur greater losses as indicated in Appendix Table 
lOh. The example assumes a high dependency of 31 percent. Producers 
with dependencies above this level will receive proportionately greater 
impacts . 


185 


Appendix 10. Summary of grazing permittee operations and impacts of implementing various alternatives on the Claries H . Russell National Wildlife 
Refuge, Montana. !/ 


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188 


impact; -“negative Impact; Ne-negL4glble . 

2/ Information from FWS (1975-79). (Filled out by respective operators; assumed to be correct. 
*C.|»ange of livestock class * high impact. 


Appendix 10 


Appendix Table 10 a. Cost and returns, beef cow 
Russell National Wildlife 

enterprises 

Refuge 

with up 

to 99 head. 

Charles 

M. 


Average 


Price 


Total 

Item Unit Number 







wei ghr 


Cur. 


Va 1 up 

Sales : 






Steer calves Head 23 

430 


71.23 


7,045 

Heifer calves Head 13 

410 


62.82 


3,348 

Yearling steers Head — 

— 


— 


— 

Yearling heifers Head 4 

680 


56.02 


1,524 

Cull cows Head 5 

950 


36.99 


1,757 

Total 





13,674 

Total/ cow 





244.18 



Total 


Value/ 


Cash ccsts: 


Value 


Cow 


BLM grazing fee 


13 


.23 


Wildlife Refuge 


167 


2.98 


D rivate range lease/rent 


451 


8.05 


State lease 


43 


.77 


Hay (produce) 


1,454 


25.96 


Hay (purchase) 


— 


— 


Protein supplement 


1,814 


32.39 


Irrigated pasture 


— 


— 


Salt and mineral 


149 


2.66 


Concentrate feeds 


— 


— 


Veterinary and medicine 


296 


5.29 


Hired trucking 


92 


1.64 


Marketing 


249 


4.45 


Fuel and lubricants 


798 


14.25 


Repairs 


574 


10.25 


Land taxes 


465 


8.30 


Other taxes 


101 


1.80 


Insurance 


87 


1.55 


Interest on operating 






capital 


367 


6.55 


General farm overhead 


458 


8.18 


Other cash costs 


— 


— 


Hired labor 


139 


2.48 


Total cash costs 


7,717 


137.80 


Other Costs: 






Family labor 


2,185 


39.02 


Depreciation 


1,665 


29.73 


Interest on investment 






Other than land 


3,504 


62.57 


Interest on land 


9,418 


168.18 


Total other costs 


16.772 


299.50 


Total all costs 


24.489 


437.30 


Return above cash costs 


5,957 


106.38 


Return above cash costs and 






family labor 


3,772 


67.36 


Return to total investment 


2,107 


37.63 


Return to land 


---1.397 


-24.95 



Production Assumptions: Average herd 56 cows; 90 percent calf crop with pregnancy 

testing; 5 percent calf loss to weaning; 20 cows per bull; 25 percent of heifer calves 
held for replacement; 4 percent cow loss; 13 percent dependent on wildlife refuge for 
annual feed. 


189 


Appendix 10 

Appendix Table 10 b. Costs and returns, beef cow enterprises with 100-199 head, Charles M. 

Russell National Wildlife Refuge 


Item Unit 

Number 

Average 
upi ghr 


Price 

Cwt 

Total 

Value 

Sales: 






Steer calves Head 

57 

430 


71.23 

17,458 

Heifer calves Head 

25 

410 


62.82 

6,439 

Yearling steers Head 

— 

— 


— 

— 

Yearling heifers Head 

12 

680 


56.02 

4,571 

Cull cows Head 

16 

950 


36.99 

5,622 

Total 





34,090 

Total/cow 





254.40 




Total 


Value/ 

Cash costs: 



Value 


Cow 

BLM grazing fee 



238 


1.78 

Wildlife Refuge 



731 


5.46 

Private range lease/ rent 



1,130 


8.43 

State lease 



113 


.84 

Hay (produce) 



2,237 


16.69 

Hay (purchase) 



— 


— 

Protein supplement 



4,212 


31.43 

Irrigated pasture 



— 


— 

Salt and mineral 



355 


2.65 

Concentrate feeds 



— 


— 

Veterinary and medicine 



712 


5.31 

Hired trucking 



261 


1.95 

Market ing 



549 


4.10 

Fuel and lubricants 



1,392 


10.39 

Repairs 



1,450 


10.82 

Land taxes 



1,154 


8.61 

Other taxes 



206 


1.54 

Insurance 



570 


4.25 

Interest on operating 






capital 



896 


6.69 

General farm overhead 



989 


7.38 

Other cash costs 



— 


— 

Hired labor 



588 


4.39 

Total cash costs 



17,783 


132.71 

Other Costs: 






Family labor 



4,307 


32.14 

Depreciation 



3,678 


27.45 

Interest on investment 






Other than land 



8,127 


60.65 

Interest on land 



26,804 


200.03 

Total other costs 



42.916 


320.27 

Total all costs 



60.699 


452.98 

Return above cash costs 



16,307 


121.69 

Return above cash costs and 






family labor 



12,000 


89.55 

Return to total investment 



8,322 


62.10 

Return to land 



L25 


1.46 


Production Assumptions; Average herd 134 cows; 90 percent calf crop with pregnancy testing; 
5 percent calf loss to weaning; 20 cows per bull; 25 percent heifer calves held for 
replacement; 4 percent cow loss; 22 percent dependent on wildlife refuge for annual feed. 


190 


Appendix 10 

Appendix Table 10 c, Costs and returns, beef cow enterprises with 200-299 head, Charles M. 

Russell National Wildlife Refuge. 


... ... Average 

Item Unit Numoer . , 

weight 


Price 

Gwt 

Total 

Value 

Sales: 




Steer calves Head 94 430 


71.23 

28,791 

Heifer calves Head 40 410 


62.82 

10,302 

Yearling steers Head — — 


— 

— 

Yearling heifers Head 19 680 


56.02 

7,238 

Cull cows Head 27 950 


36.99 

9,488 

Total 



55,819 

Total/cow 



252.57 


Total 


Value/ 

Cash costs: 

Value 


Cow 

BLM grazing fee 

301 


1.36 

Wildlife Refuge 

873 


3.95 

Private range lease/rent 

1,459 


6.60 

State lease 

123 


.56 

Hay (produce) 

4,474 


20.24 

Hay (purchase) 

2,105 


9.52 

Protein supplement 

1,789 


8.10 

Irrigated pasture 

— 


— 

Salt and mineral 

597 


2.70 

Concentrate feeds 

— 


— 

Veterinary and medicine 

1,059 


4.79 

Hired trucking 

298 


1.35 

Marketing 

373 


1.69 

Fuel and lubricants 

1,841 


8.33 

Repairs 

2,128 


9.63 

Land taxes 

1,843 


8.34 

Other taxes 

298 


1.35 

Insurance 

928 


4.20 

Interest on operating 




capital 

1,410 


6.38 

General farm overhead 

1,478 


6.69 

Other cash costs 

— 


— 

Hired labor 

2,060 


9.32 

Total cash costs 

25,437 


115.10 

Other Costs: 




Family labor 

7,585 


34.32 

Depreciat ion 

2,339 


10.58 

Interest on investment 




Other than land 

13,215 


59.80 

Interest on land 

39,338 


178.00 

Total other costs 

. _ 62^477 


282.70 

Total all costs 

87,914. 


397.80 

Return above cash costs 

30,382 


137.48 

Return above cash costs and 




family labor 

22,797 


103.15 

Return to total investment 

20,458 


92.57 

Return to land 

7 74a 


37.77 

Production Assumptions: Average herd 221 cows; 9U 

percent calt crop with 

pregnancy 

testing; 5 percent calf loss to weaning; 20 cows per 

bull; 25 

percent of heifer calves 

held for replacement; 4 percent cow loss; 17 percent 

dependent 

on wildlife 

refuge for 


annual feed. 


191 


Appendix 10 


Appendix Table 10 d, Costs and returns, beef cow enterprises with 300 
Russell National Wildlife Refuge. 

head or more, Charles M. 

„ Average 

Item Unit Number . , 


Price 

Total 

__ ... weight 


Cwt 

Va 1 ne 

Sales: 




Steer calves Head 400 430 


71.23 

122,516 

Heifer calves Head 166 410 


62.82 

42,755 

Yearling steers Head — 


— 

— 

Yearling heifers Head 82 680 


56.02 

31,237 

Cull cows Head 115 950 


36.99 

40,412 

Total 



236,920 

Total/cow 



253.12 


Total 


Value/ 

Cash costs: 

Value 


Cow 

BLM grazing fee 

2,982 


3.19 

Wildlife Refuge 

2,113 


2.26 

Private range lease/rent 

6,665 


7.12 

State lease 

561 


.60 

Hay (produce) 

13,980 


14.94 

Hay (purchase) 

6,416 


6.85 

Protein supplement 

10,080 


10.77 

Irrigated pasture 

— 


— 

Salt and mineral 

2,527 


2.70 

Concentrate feeds 

— 


— 

Veterinary and medicine 

4,483 


4.79 

Hired trucking 

1,264 


1.35 

Market ing 

1,582 


1.69 

Fuel and lubricants 

6,234 


6.66 

Repairs 

6,243 


6.67 

Land taxes 

8,518 


9.10 

Other taxes 

1,320 


1.41 

Insurance 

2,902 


3.10 

Interest on operating 




capital 

4,754 


5.08 

General farm overhead 

4,399 


4.70 

Other cash costs 

— 


— 

Hired labor 

7,582 


8.10 

Total cash costs 

94,605 


101.07 

Other Costs: 




Family labor 

24,800 


26.50 

Depreciation 

24,026 


25.67 

Interest on investment 




Other than land 

58,961 


62.99 

Interest on land 

134.392 


197.00 

Total other costs 

292,179 


312.16 

Total all costs 

386.784 


413.23 

Return above cash costs 

142,315 


152.05 

Return above cash costs and 




family labor 

117,515 


125.55 

Return to total investment 

93,489 


95.88 

Return to lan^ 

34.528 


36.89 

Production Assumptions: Average herd 936 cows; 90 

percent calf 

crop with 

pregnancy testing; 

5 percent calf loss to weaning; 20 cwos per bull; 25 

percent of 

heifer calves held for 

replacement; 9 percent dependent on wildlife refuge 

for annual feed. 



192 


Appendix 10 


Appendix Table lOe-Estimated annual reduction in selected inputs, costs, 

and returns, from alternative livestock forage supplies, 
Charles M. Russell National Wildlife Refuge 





A1 

ternative Actions 




Item 

Propose d 
Action 

Intensive 

Wildlife 

Multipl 

Use 

S I/ 

No 

Grazing 


1990 

2005 

199Q 

2005 

1990 

2005 

1990 

2005 





Thousand Dollars 




Gross income 

347 

352 

725 

641 

249 

79 

567 

1,122 

Cash expenditures 

85 

86 

178 

158 

61 

19 

140 

276 

Return above 
cash costs 

262 

266 

547 

483 

188 

60 

427 

846 






Head 




Cows 

1.377 

1.393 

2,863 

2.537 

983 

315 

2,244 

4,439 






Man Years 




Family labor 

5.1 

5. 1 

10.7 

9.4 

3.6 

1.1 

8.4 

16.5 

Hired labor 

1.4 

1.4 

2.8 

2.5 

.9 

.3 

2.2 

4.4 






Percent 




Reduction in forage 

-33 

-33 

-67 

-60 

-26 

-12 

-54 

-100 


1 / There are 7,500 unallocated AUMs with this alternative, 
these may be used by present Refuge users. 


About one-half of 


193 


Appendix 10 


Appendix Table 10f-Ef feet of changes in forage supplies upon total cash 

costs per cow, Charles M. Russell National Wildlife Refuge - 


Reduction 
in Refuge 
grazing 
(Percent) 


Herd size 



0-99 

100-199 

200-299 

300 and over 



Dollars /cow 


No change 

137.80 

132.71 

105.50 

101.07 

30 

140.50 

137.37 

117.21 

102. 19 

50 

142.36 

140.86 

119.22 

102.96 

100 

147.69 

151.42 

124.98 

105.02 

1/ See tables 

1-4 for specific 

items included as cash 

costs . 



194 


Appendix 10 


Appendix Table 10g-Distribution of producers by herd size and 

dependency on Refuge grazing 


Dependency 


(percent) 

0-99 : 

: J 00-199 : 200-299 

: 300 

and over: 

:A11 sizes 




Percent of 

producers 


C -10 

17 

26 

42 


43 

36 

11-20 

58 

21 

26 


38 

34 

21-30 


32 

16 


8 

14 

31-50 


16 

11 


11 

10 

51 and over 

25 

5 

5 



6 

Total 

100 

100 

100 


100 

100 




Percent of 

annual 

feed 


Average 

dependency 

13 

22 

17 


9 

13 


Appendix Table lOh-Impact on return above cash costs of proposed 
action, by herd size and dependency 


Reduction in return above cash costs 


Herd size Average High depend^ycy 

(head) producer producers— 



Dollars 

Percent 

Dollars 

Percent 

0-99 

385 

6 

y 

2/ 

iOO-199 

1,700 

10 

2,300 

14 

200-299 

4,200 

13 

7,800 

24 

300 and over 

4,900 

3 

18,500 

13 


1/ Indicated reductions in return above cash costs assume 31 percent 
dependency. Since at high dependency producers are above this percent- 
age, their losses of return above cash costs will exceed these values. 

2/ High dependency producers have less than 12 cows and should not 
be seriously impacted by reductions. 


195 


Appendix Table lOi-Impacts of incremental adjustments in forage, Charles Russell National Wildlife Refuge, 

0-99 cows, average 56 head 


Appendix 10 





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196 


Hired Labor 


Appendix Tabl e lOi- (Continued) 


Appendix 10 




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197 


Appendix TablelO j -Impacts of incremental adjustments in forage, Charles Russell National Wildlife 

Refuge, 100-199 cows, average 134 head 


Appendix 10 













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198 


Family Labor 1,148 1,136 1,123 1,110 1,097 1,084 1,072 1,059 

Hired Labor 157 155 153 152 150 148 146 145 


Appendix Table 10j — (Continued) 


Appendix 10 




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On 

CO 


^d- 

vO 

r^. 

vO 

o 

£ 


rH 

o 


CM 

ON 

ON 


CM 

ON 

ON 

ON 

rH 

o 

o 

o 

CO 


00 

UO 

CM 


U0 

vO 

o 

rH 

• 


U0 

Q 

r 


* 

<» 

•* 



«* 


r 

ON 

AJ 


O 

vO 

CO 

CO 



CO 

ON 

vO 

rH 

rH 

a 


CO 

rH 





rH 



| 

rH 

3 













T3 













CU 













PC 













AJ 













3 













CU 













a 













j-j 













<U 


-d- 

vO 

uo 

r-* 

uo 


00 

CO 

vO 

ON 

r". 

Pj 




p-* 

O 

c«. 


ON 

CM 

rH 

in 

uo 


LO 

v£> 

CO 

00 

vO 

CO 


P^ 

ON 

CO 

c 

• 


<r 

** 

*» 

r* 

*» 

r 


•* 

r 

»> 


O 



O 

vO 

CO 

CO 



co 

ON 

vO 

rH 

CM 



CO 

rH 





rH 




rH 




UO 

CM 

uo 

O' 


CM 

o 

UO 

CM 

<f 





CM 

rH 

uo 


C- 

uo 

CO 

CM 

O 


o 

o 

on 

on 

vO 

<r 


O 

rH 

U0 

ON 

• 


S3- 

M 

« 

* 

*» 

r 



•* 

*» 

1 

CM 



rH 

vO 

CO 

CO 



<r 

o 

vO 


CM 



CO 

rH 





rH 

rH 



rH 







AJ 











V-» 


c 











o 


a) 













6 











03 


AJ 











rH 


C/3 T3 










CO 



QJ C 










AJ 



> 03 




rH 






CO 

rH 


3 rH 



T3 H 

03 

no 





o 

*H 


•H 

• • 


3 O 

AJ 

0 




<U 

u 

B 

o 

c 

a> 


03 -Q 

O AJ 

o 




e 


03 

o 

3 O 

> 


03 

AJ C 

rH 




o 

JC 

U-l 

•H 

0 J= 

o 

cn 

W rH 

o 





u 

CO 


AJ 

AJ 

rO 

AJ 

AJ 

O E 

o 

a) 



o 

Cfl 

u_| 

03 

AJ 

03 

cn 

cn >> 

A» AJ 

AJ 

CM 


E 

*H 

u 

O 

■H 

cn 3 


o 

O rH 

cn 


•H 

a; 




U 

QJ QJ 

3 

u 

U *H 

3 0J 

3 

cn 


LJ 

CO 

rH 

<U 

<u 

H J3 

Li 


E 

H > 

Li 


M 

CO 

CCJ 

3 

Li 

QJ AJ 

3 

£2, 

3 

3 3 

3 

T3 



o 

AJ 

rH 

CL 

AJ O 

AJ 

CO 

cn u_i 

AJ -H 

AJ 

Li 



V4 

o 

03 

(U 

3 

a) 

O 

03 

CU 

0) 

0) 



a 

H 

> 

Q 

LH 

C*3 

CJ 

O 

a; 

O' 

X 


vO 

00 


CM 

on 

00 


CO 

co 

o 


vO 

<r 

o 

rH 


U 

o 

no 

CvJ 

rJ 

rH 

•H 

6 

03 

Pu 


199 


Hired Labor 143 141 139 122 159 160 162 


Refuge, 200-299 cows, average 221 head 


03 

<-W 


“O 

rH 

•H 


03 

2 


rH 

<u 


4-r 

O 

03 


0 
CO 

a 

E 

M 

1 


o 


a) 


« 

H 

X 

T 3 

C 

<u 

Q. 

Q. 

< 




<■ 

rH 


00 


SO 


co 

sO 


00 

04 

co 





ON 

sO 

CM 

sO 


SO 


co 

O 


CO 


00 

O 



uo 

*d- 

<r 

rH 

CM 


<r 


o 

Os 


sO 

rH 

• 

O 



co 

A 

a 

a 

* 


a 


A 

* 


* 



Os 

sO 



CM 

<* 

r*. 

CM 


CM 


00 

o 


00 

sO 

o 

A 

rH 



m 

CM 




rH 


CM 

CM 


rH 


CM 

rH 

in 



CO 

CM 

CM 

00 


CM 


.H 

Os 


rH 

Os 

CO 






00 

os 

r^. 




OS 

OS 


CM 

MT 


00 



c 


m 

rH 

CM 


m 


oo 

rH 


OS 

CO 

• 

rH 



co 

* 

a 

a 

r> 


** 


a 

* 



* 

Os 

OS 

rH 



CM 

>d* 


CM 


CM 


oo 

rH 


00 

sO 

O 

A 

CM 



in 

CM 




rH 


CM 

CM 


rH 


CM 

rH 

in 




OS 

o 

Os 


CO 


m 

in 


sO 

CO 

rH 






o 

sO 

00 


00 


so 

o 


rH 

CO 

r^- 

sO 



in 

<r 


CM 

CM 


sO 



in 


CM 

uo 

• 

CO 



CM 

•* 

a 

a 

a 


a 


a 

*• 


* 

* 

rH 

Os 

so 



CO 

-d- 


CM 


CM 


co 

rH 


Os 

sO 

rH 

A 

CM 



m 

CM 




rH 


CM 

CM 


rH 


CM 

rH 

in 

03 

















c 

















o 

















•H 

















4J 

















O 

















3 

















-o 


•'d* 

o 

uo 

Os 


OS 


<r 

Os 


o 

rH 

rH 



03 


m 

CO 

CM 

Os 


00 


CM 

OS 


o 

rH 

SO 

CO 


PC 

o 

os 

oo 

CO 

CM 


r*. 


rH 

r*. 


m 


• 

m 



CM 

*> 

A 

a 

a 


a 


a 

a 


* 

* 

CO 

Os 

rH 

u 


CO 

*d- 


CM 


CM 


Os 

rH 


Os 

sO 

rH 

A 

co 

c 


in 

CM 




rH 


CM 

CM 


rH 


CM 

rH 

in 

cu 

















u 

















u 

















a) 

















Ph 



















"d- 

CM 

O 

OS 


sO 


CM 

CM 


CO 


rH 





CO 

m 

Os 

O 


Os 


00 

Os 


00 

00 

uo 

rH 



m 

'd- 

os 

co 

CO 


00 


'd* 

O 


p>- 

oo 

• 




rH 

a 

a 

A 

a 


a 


a 

** 


** 

• 

in 

O 

so 



03 

<r 

^d- 


CM 


CM 


Os 

CM 


Os 

sO 

rH 

A 

co 



M 

m 

CM 




rH 


CM 

CM 


rH 


CM 

rH 

n 



c0 


















rH 


















rH 


















o 


















Q 


















CO 

CO 

m 

Os 


CM 


c 

m 


SO 

'd- 

rH 





rH 

p>« 

m. 

rH 


o 


HT 

oo 


sO 

sO 

<r 

00 



O 

Os 

o 

'd* 

CO 


o 


00 

co 


o 

o 

• 

00 



rH 

a 

A 

a 

a 


A 


• 

A 


A 

• 


O 

O 



<■ 

m 


CM 


CO 


Os 

CM 


o 


rH 

A 




m 

CM 




rH 


CM 

CM 


CM 


CM 

rH 

in 



CO 

'd* 

O 

Os 


00 


Os 

OS 


O 

CM 

rH 





os 

Os 

CM 

CM 


o 


Os 

r^. 


m 

^d* 

CO 

in 




CO 

rH 

m 

CO 


»H 


rH 

SO 


co 

CM 

• 

o 



m 

* 

a 

a 

a 


* 


a 

A 


• 

A 

Os 

o 

n 



m 

m 

r>. 

CM 


CO 


o 

CM 


o 

n* 

rH 

A 

>d* 



m 

CM 




rH 


CO 

CM 


CM 


CM 

CM 

uo 


0) 

co 

sO 

m 

OS 


m 


r^. 

CM 


CO 

00 

•H 




oc 


rH 

00 

CO 


rH 


in 



co 

rH 

CM 

CO 


o 

c 

00 

CO 

m 

CO 


CM 


in 

OS 


sO 

<* 

• 

CM 


2 

CO 

* 

a 

a 

a 


a 


•» 

A 


* 


rH 

o 

o 


J= 

m 

CO 


CM 


CO 


CM 

-d* 


CM 

Os 

CM 

A 

n 


u 

m 

CM 




rH 


CO 

CM 


CM 


CM 

CM 

in 







u 















u 


C 















o 


0) 















JO 


E 















CO 


4J 















rH 


CO 

*3 













03 



qj 

C 













4-1 

r*N 


> 

3 




»H 









03 

*H 


a 

rH 



T 3 U 

3 


*T3 







O 

•H 


•H 


• • 


C C 

i-i 


C 






a> 

U 

E 

C 


c 

<u 


3 

0 

U 

3 






e 


co 

o 

c 

aj 

> 


3 

u 

C 

rH 


H 




o 

js 

UH 

H 

o 

x: 

0 

03 

03 rH 


03 



O 




u 

03 


4-1 


u 

X) 

U 

U 

C 

E 

o 

03 

-O 

0 



c 

CO 

U_J 

<0 

4J 


03 

0) 

03 

■u 

u 

iJ 

N 

3 

J0 

E 

•H 

a 

o 

TH 

CO 

u 


o 

O rH 


0) 


•H 

r-3 

3 

0) 




CJ 

<y 

<u 

3 

CJ 

O *H 

C 

03 

c 

C/3 



4J 

03 

rH 

0) 

<u 

i-r 

XT 

U 


E 

U 

> 

u 


>* 


M 

03 

03 

3 

u 

a; 

4-1 

3 

X 

x: 03 

3 

C 

3 

*3 

rH 

T1 



O 

u 

rH 

Q. 

4J 

0 

4J 

03 

03 sm 

4-1 

H 

4-1 

H 

•H 

0/ 



H 

O 

c0 

a> 

a 


a> 

3 

3 

03 


0) 

03 

E 

V-r 



<J 

H 

> 

Q 

hH 



CJ 

o 

Q2 


oz 

X 

3 

*H 

T. 


Appendix 10 


200 


Appendix Table 10k - (Continued) 




in 

pH 

w 

oo 

ri 

00 

sO 

cn 


cn 

r-i 

m 

00 

Mf 

r-r 

ON 

m 



m 

cn 

sO 


cn 

m 


sO 

oo 

*3* 

a. 

• 




rH 

•* 

p 

•* 

p 

•* 


p 

p 

p 

p 

sO 

o 

*3- 




m 


CM 

cn 


rH 

cn 

pH 


CM 

p 

vO 



m 

CM 



rH 


cn 

CM 

CM 


CM 


m 

CO 















V 















CO 















CO 















0) 















u 


cn 

ON 

sO 

ON 

00 


*3- 

00 

ON 

rH 

pH 



o 


cn 

in 

rH 

m 

CM 



in 

ON 


O 



c 

O 

00 

m 


cn 

>3- 


CM 

m 

pH 

r*^ 

• 

in 


W 

r-H 

p 

p 

* 

p 

p 


p 

p 

p 

p 

m 

O 

o» 



sO 

m 

r^ 

CM 

cn 


pH 

cn 

pH 


CM 

p 

i n 

•u 


m 

CM 



rH 


cn 

CM 

CM 


CM 

CM 

i r, 

c 















0) 















1 CJ 















u 















<y 
































cn 


O 

ON 

rH 


VO 

NO 

r^* 

NO 

rH 





m 

cn 

m 

"3- 

CM 


pH 

vO 

rH 

ON 

rH 

o 




cn 


so 

cn 

cn 


On 

CM 

ON 

m 

• 

<■ 



m 

p 

p 

P 

•* 

r 


p 

p 

p 

p 

cn 

o 

<r 



SO 

m 


CM 

cn 


o 

cn 

o 


CM 

p 

m 



m 

CM 



rH 


cn 

CM 

CM 


CM 

CM 

m 



in 

r>- 



00 


00 

rH 

^3- 

NO 

m 





cn 

n* 


cn 



m 

00 


sO 

o 

>3- 



o 

CM 

00 

CM 

rH 

O 


cn 

o 

ON 

00 

• 




o 

p 

p 

•* 

p 

p 


p 

p 

p 

p 

cn 

so 

m 


pH 

sO 

CM 

vO 

CM 

pH 


cn 

1^ 

-3* 

cn 

oo 

p 

&n 



■<r 

CM 



pH 


CM 

rH 

rH 


rH 

rH 

^3- 



CO 
















M 
















G 
















rH 

^3- 


rH 

00 

sO 



so 

00 

CM 

cn 





rH 

m 

ON 

cn 

cn 

<r 


m 

CM 

oo 

'O 

pH 

00 



o 

o 

o 

o 

ON 

CM 

pH 


ON 

O 

r-v 

sO 

• 

^3* 


CO 

m 

o 

•> 

p 

p 

p 

p 


p 

p 

p 

p 

CM 

00 

CM 

c 


rH 

HT 

sO 

CM 

CM 


sO 

o 

r>- 

m 

o 

p 

o 

o 


in 

CM 



pH 


CM 

CM 

rH 


CM 

pH 

m 

*H 















4-1 















o 















3 






























cu 















c* 















u 















G 

0) 


^3" 

00 

sO 

oo 

cn 


sO 

o 

CM 

ON 

cn 



CJ 


cn 

rH 

ON 

>3* 

m 


rH 

CM 

r** 

rH 

o 

‘X) 


>h 

m 

m 

CM 

ON 

CM 

CM 


cn 

cn 

o 

00 

• 

sO 


0) 

<r 

•* 

P 

P 

p 

p 


« 

p 

p 

p 

<• 

00 


X 


rH 

>3* 

sO 

CM 

CM 


r*. 

o 

00 

m 

o 

p 

o 



m 

CM 



pH 


CM 

CM 

rH 


CM 

rH 

m 




On 

rH 

00 

ON 


m 

>3- 

sO 


cn 





rH 

cn 

sO 

m 

m 



rH 

m 

ON 

ON 

cn 



o 

o 

cn 

O 

CM 

cn 


sO 

NO 

cn 

ON 

• 

oo 





A 

P 

p 

p 


p 

p 

p 

p 

m 

00 

CM 



CM 

<r 


CM 

CM 


r- 

o 

00 

in 

o 

p 

rH 



in 

CM 



pH 


CM 

CM 

pH 


CM 

pH 

m 







U 













U 


c 













O 


Q) 













JO 


e 













G 


u 













rH 


cn 73 












CO 



a) c 












u 

Sn 


> G 




H 








(0 

rH 


C rH 



73 M 

G 

73 







o 

•H 


•H 

• • 


C O 

4-1 

c 






a> 

CJ 

e 

C 

c 

< V 


G JO 

O U 

G 


H 




B 


g 

o 

C G 

> 


G 

4J C 

rH 


O 




O 

J= 

u-l 

•H 

0 X 

o 

cn 

cn rH 

Q) 



JO 

o 



CJ 

CO 


LJ 

u 

JO 

u 

u 

O S 

o 

a> 

G 

J0 



c 

G 

u-i 

G 

4-1 

G 

cn 

cn >> 

4J 4J 

4-> 

N 

•— 3 

G 


5 

•H 

a 

O 

•H 

cn »-• 


o 

O rH 

cn 


*H 


rJ 

a> 




O 

•u G 

G 

a 

J *H 

C 0) 

G 

V) 

>s 



-i 

CO 

rH 

a) 

0) 

u X 

u 


6 

H > 

u 


rH 

73 

»-h 

CO 

G 

3 

u 

a> u 

3 

si 

J= G 

3 C 

3 

73 

*H 

(1) 



o 

XJ 

rH 

CL 

u o 

4J 

c n 

cn u-* 

4J *H 

LJ 


s 

M 



M 

O 

CO 

0) 

c 

(1) 

G 

G 

G 

G 

O 

G 

•H 



CJ 

H 

> 

a 

l-H 

as 

CJ 

CJ 

OS 

QS 

2C 


"X 


Appendix 10 


201 


Appendix Table 10 1-Inipacts of Incremental adjustments in forage, Charles Russell National Wildlife Refuge, 

300 or more cows, average 936 bead 




nO 

on 

<r 

on 


rH 


on 

ON 


NO 

in 






p^ 

in 

*n 



<r 


CN 

00 


rH 


in 





o 

0© 

o 

00 


on 


CN 

rH 


on 

ON 

ON 

CN 

On 


m 

• 

** 

** 

•* 


* 


•* 



* 

r« 

• 

H 

un 


cn 

ON 

CN 

<T 

cn 


r>. 


NO 

CN 


oo 

o 

NO 

<r 

ON 



CN 

ON 

TN 

CN 


in 


on 

rH 


oo 

cn 

o 


* 



CN 







rH 

rH 




ON 

NO 

rH 



CN 

<r 

"3* 

in 


on 


oo 

<r 


ON 

NO 






CN 

o 

<r 

ON 


p^ 


rH 



r-* 

o 

ON 





rH 

rH 

rH 

CO 


n 


O 

oo 


ON 

<r 

o 

rH 

OC 


c 

• 


«* 

p> 


•* 


•* 

r> 


**■ 

•» 

• 

<r 

NO 


on 

o 

on 

<r 

on 


p^ 


P^. 

CN 


oo 

rH 

H 

<r 

ON 



on 

ON 

CN 

CN 


n 


on 

rH 


oo 

cn 

H 

•* 

** 



CN 







rH 





ON 

NO 

rH 



00 

in 

"3- 

P^ 


in 


on 

ON 


CN 

r^«. 






vO 

in 

un 

rH 


o 


rH 

n 


>3- 

cn 

cn 





r— 1 

on 

CN 

ON 


oo 


00 

in 


NO 

00 

CN 

rH 



n 

•* 

* 

*» 

•* 


•» 



* 



*» 

• 


p>* 


CN 

rH 

on 

<r 

on 


r«. 



on 


ON 

rH 

in 

**3* 

ON 



on 

ON 

CN 

CN 


m 


cn 

rH 


00 

m 

rH 

** 

« 



CN 







rH 

rH 




ON 

NO 

rH 

Cfl 

















C 

















o 

















•H 

















Li 

















< J 

















3 


nO 

CN 

ON 

OO 


cn 


^3* 

CN 


<r 

rH 




*o 


ON 

o 

nO 

on 


on 


ON 

on 


ON 

NO 

O 



0J 


rH 

nO 

on 

ON 


O 


in 

CN 


CN 

CN 

cn 

ON 

NO 

a: 

o 


*» 

•* 

•» 


*> 


* 

• 



** 

• 

ON 

CO 


CN 

CN 

on 


on 


00 


oo 

<r 


O 


ON 


ON 

L» 


on 

On 

CN 

CN 


in 


cn 

rH 


ON 

cn 

rH 

* 

•*- 

c 


CN 







rH 

rH 




ON 

NO 

rH 

aj 

















a 

















Li 

















a) 

















cu 



















CN 

ON 

•H 

O 


m 


o 

ON 


ON 

^3- 






>3- 

m 

r>. 

nO 


NO 


ON 

«H 


in 

ON 

n 





CN 

oo 

<■ 

ON 


CN 


on 

ON 


ON 

NO 

^3* 

ON 

un 


in 

•* 

• 

•* 

•* 


* 


•» 

** 


•* 

•» 

• 

CN 

ON 


rH 

on 

on 


on 


oo 


ON 

"3" 


o 

CN 

cn 

in 

On 



cn 

on 

ON 

CN 

CN 


in 


on 

rH 


ON 

cn 

CN 

** 

** 



u 

CN 







rH 

rH 




ON 

NO 

rH 



a3 


















rH 


















rH 


















o 


















Q 


















ON 

on 

»H 

CN 


p^ 


NO 

in 


cn 

NO 






00 

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— 


Appendix 10 


202 


Appendix Table 10 1- (Continued) 


Appendix 10 


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Income in the six-county region at Charles M. Kussell National Wildlife Refuge, Montana 


Appendix 11 


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204 


(D)-Not shown to avoid disclosure of confidential information, data included in totals. (L)-I.ess than $50,000, data included in totals. 


Appendix 12. Number of persons 14 years or older employed lntlie six-county region of Charles M. Russell National Wildlife Refuge, Montana, 
1960 and 1970.- 


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205 


Appendix 13 


Appendix 13. Estimation of indirect economic impacts. 
Introduction 


An interindustry model is used to identify the interdependent 
structure of the local economy surrounding the Charles M. Russell 
National Wildlife Refuge. The interindustry model, commonly called an 
input-output model, is used to measure the structural interdependence 
among producing sectors within the region. The input-output technique 
shows what changes in one sector (livestock) will have on activities in 
the other sectors. 

The model is governed by what are termed final demands. Changes in 
the production by basic industries which export goods and services to 
customers from outside the study region determine the level of economic 
activity within the region. Thus, changes in the export of livestock 
and changes in the sale of goods and services to tourists constitute 
changes in final demand. The primary purpose of the input-output tech- 
nique is to trace the direct and indirect impacts of such changes in 
final demand throughout the local economy. A more detailed description 
of the input-output technique can be found in Richardson (1972). 

Procedures Followed 


The input-output method of analysis results in the calculation of 
"multipliers" which can be applied to projected changes in exports by a 
given industry in order to calculate the direct plus indirect economic 
impacts on a regional economy. Total sales, personal income, and employ- 
ment are among the set of important impacts which may be calculated 
through the use of input-output multipliers. 

Two major direct effects are foreseen as a result of the proposed 
alternative. One direct impact is on the level of livestock production 
in the study region. This economic impact has been reviewed through the 
use of linear programming analysis and is reported elsewhere in this 
report. The second direct impact is in the level of tourist activity in 
the study region. The changes in tourist visitation predicted in the 
Draft EIS are retained, but new estimates of purchases in the study 
region by tourists are used to calculate changes in sales to tourists. 

Once the direct changes in business activity in the livestock and 
tourist industries have been estimated, input-output multipliers are 
used to find the total (direct plus indirect) impacts on the local 
economy . 

Selection of Appropriate Multipliers 

The construction of an input-output model is a time-consuming and 
expensive process. Neither time nor available finances would allow 
development of a model specific to the study region. No models presently 
exist specifically of the study region although some models are under develop- 
ment which might be used in the future. Multipliers for the livestock 

^The Forest Service 1-0 model based upon secondary data as used in the pre- 
vious Draft EIS is not currently available. An economic base model is 
currently under construction, but is unavailable at this time. 


206 


Appendix 13. (Coni’ d.) 


sector and for sectors most affected by tourist spending have been taken 
from a recent study conducted in Colorado near Kremmling. The Kremmling 
study is for a relatively isolated and small regional economy in Colorado. 

It is the most recent survey-based input-output model available to the 
researchers for this report. Since it was developed by researchers, it 
has the added advantage of familiarity with the details of its construc- 
tion. Appendix Table 13a presents a distribution of employment by 
industry in the CMR study region and the Kremmling for comparison. It 
may be noted that the absolute size of the local economy in the Kremmling 
model is smaller than in the CMR study region. Generally, the estimated 
indirect impacts will increase as the size and self-sufficiency of the 
region is increased. Thus, the multipliers taken from the Kremmling 
study may slightly understate the total impacts on the CMR study region. 

Such a generalization may not always apply, however, since some indus- 
tries may benefit from the lack of competing suppliers due to the geo- 
graphic isolation of a region. Alternative livestock industry i^put- 
output multipliers can be found in Bartlett, Taylor, and McKean. 

A unique sector is seldom available for the tourist industry. This 
does not present a significant problem, however, since a weighted multi- 
plier is easily calculated. The recent survey of tourists in Wyoming ^ 

(1979), identified ten sectors or industry groups selling to tourists. 

The large sample size of 2,766 and the fact that the survey is very 
current and in a neighboring state, make this data most appropriate for 
weighting the multipliers. Multipliers taken from the Kremmling study 
are aggregrated using spending shares from the Wyoming tourist survey. 

These calculations are presented in Appendix Table 13b. A weighted 
business multiplier and weighted employment multiplier are calculated 
for tourist spending. 

It should be noted that a Type II multiplier was used to estimate 
the total impacts of changes in livestock production, while a Type I 
multiplier was used in conjunction with the tourist spending estimates. 

A Type II multiplier for livestock is appropriate given that virtually 
all livestock production is exported from the study region, and maximum 
expected impact measurement is desired. To the extent that households 
do not respend a fixed proportion of their incomes inside the study 
region, the Type II multiplier could overstate the total impact. 

A Type I multiplier was used for the tourist impact measurement 
because it was not possible to identify tourist exports. Rather, total 
spending by households, both local and export, was multiplied by the 
Type I multiplier. Because of a lack of export data, it was necessary 
to assume that households are exogenous when estimating tourism impacts. 

With this assumption, total household spending rather than only export 
spending could be utilized in the impact measurement. A smaller multi- 
plier was thus applied to the larger tourist spending estimates. Appendix 
Tables 13c-e show total or direct plus indirect effects of the management 
alternatives on sales and employment. 

2 

Taken from: Impacts of Federal Grazing on the Economy of Colorado , by E.T. 

Bartlett, R.G. Taylor, and John McKean, Contract Report, U.S. Forest Service, 

Bureau of Land Management and Colorado State Experiment Station. 

3 

The Wyoming Travel/Tourism Industry , Industrial Development Division, 

Department of Economic Planning and Development, July 1980. 


207 


Appendix 13 


Appendix 13. (Cont’d.) 

Summary of Findings 

Total regional impacts of change in livestock production caused by the 
management alternatives are shown in Appendix Table 13c. Total impacts 
of change in tourism caused by the management alternatives are shown in 
Appendix Table 13d. Appendix Table 13e shows the combined impacts from 
changes in livestock production and tourism for each of the management 
alternatives . 


208 


Appendix 13 


Appendix Table 13a. 

Distribution of Employment by Sector, Kremmling Region, 


C.M. Russell Region 


1 ? 

Sector Description SIC Codes Kremmling Employment C.M. Russell Employment ’ 


Ag/Livestock 

01, 02, 07 

81 

29-73 

Mining 

12, 13 

111 

19-52 

Construction 

14-17 

215 

308-326 

Manufacturing 

20-39 

267 

389-425 

Transport, Comm., 
Public Utilities 

40-49 

125 

318-415 

Wholesale 

50, 51 

809 

575-654 

Retail 

52-59 


1741 

Finance, Insurance, 
Real Estate 

60-69 

152 

372-469 

Services 

70-89 
exclu. 82 

925 

1,629-1,64' 



4 

4 

Totals 


2,685 

5 , 552 


^Source: An Input-Output Model of the Kremmling Region of Western Colorado , Contract 

Report, Bureau of Land Management, Economic Department, Colorado State University, 
Fort Collins, Colorado, John R. McKean and Joseph Wever, 1980. 

^Federal disclosure law requires presentation of ranges rather than actual employment 
numbers in certain counties with small numbers of firms. 

•^Source: County Business Patterns - -MONTANA, Table 2. Counties- -Employees, Payroll, 

and Establishments, by Industry, 1977. 

^Excludes employment in educational services and government. 


209 


Appendix 13 


Appendix Tablel3b 

Estimation of Weighted Average Multipliers for Tourist Spending for All 
Recreation Activities 


Industry 

Spending Per Person'*' 

Percent 

Business Mult. 

? 3 2 

. Employment Mult. 

Lodging Places 

$5.18 

16.88 

2.58 

.865 x 10 ' 4 

Eating § Drinking Places 5.15 

16.79 

1.73 

.562 x 10 ' 4 

Auto Service 

0.97 

3.16 

1.52 

.167 x 10 ' 4 

Gasoline 

5.75 

18.74 

1.52 

.167 x 10 ' 4 

Food Stores 

3.19 

10.40 

1.42 

.160 x 10' 4 

Apparel Stores 

3.02 

9.84 

1.42 

.160 x 10' 4 

Dept. 5 Variety 

1.08 

3.52 

1.42 

.160 x 10' 4 

Amusement Places 

3.25 

10.59 

1.90 

.352 x 10 ' 4 

Drugs, Liquor § Sporting Goods 1.82 

5.93 

1.42 

.160 x 10' 4 

4 

Miscellaneous 

1.27 

4.15 

2.14 

.522 x 10 ' 4 


TOTAL 30.68 100.00 1.77 .383 x 10 

Weighted Business Weighted Employment 
Multiplier Multiplier 


^Source: The Wyoming Travel/Tourism Industry , Industrial Development Division, Department 

of Economic Planning and Development, July 1980. 

"Source: An input-Output Model of the Kremmling Region of Western Colorado , Contract Report, 

Bureau of Land Management, Economics Department, Colorado State University, Fort Collins, 
Colorado, John R. McKean and Joseph Weber, 1980. 

\ Type I business and employment multiplier is used because the portion of tourist visits 
from outside the study region is unknown. A Type I multiplier includes households in the 
exogenous part of the input-qutput model. The Type I multiplier is smaller than the Type 
II multiplier but it is the appropriate measure when exports to tourists cannot be 
seperated from local consumer spending. In effect, a smaller mutliplier is being applied 
to a larger change in spending than would be the case with a Type II multiplier on exports. 

4 

Assumed to be other services. 


210 


Appendix 

Table 13 c Direct Plus Indirect Inpacts of Change in Livestock Production on Sales and Employment. 


Appendix 13 


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211 


Appendix 

Table 13dl)irect Plus Indirect Impacts of Change in Tourist Visits on Sales and Employment. 


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212 


Source: Weighted average of multiples for goods purchased by tourists. See text and Table 


Appendix 13 


Appendix 

Table p 3 e Total Impacts of Change in Livestock Production and Tourism. 


Management 

Alternatives 


Total Change in Sales 

Total Change in Employment 

Proposed Action 

1985 

$ -763,579 

- 9 


2000 

-451,320 

- 2 

Intensive Wildlife 

1985 

-2,098,661 

-31 

Management 

2000 

-2,797,542 

-48 

Multiple Use 

1985 

+13,187 

+ 5 


2000 

+1,635,392 

+57 

No Grazing 

1985 

-1,242,372 

-15 


2000 

-2,398,400 

-30 

Source : Calculated 

from data 

shown on Tables 3 and 4. 



213 


Appendix 14 


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215 


Appendix 15 


Appendix 15. Methodology employed in calculation of AUMs on Charles M. 
Russell National Wildlife Refuge. 

Summary 

Forage allocation on the refuge consisted of four major steps. 

Step I 

A standard SCS Range Site and Condition Survey was completed on the 
refuge. This survey gave the beginning AUM recommendation. 

Step II 

Mackie's work (1970) provided the basis for this step. Using a 
slope/water matrix developed from livestock observations, availability 
coefficients were computed and applied to AUM recommendations derived 
from SCS stocking guides in Step I. This provided for proper use of 
vegetation by livestock on those areas actually grazed instead of assuming 
even livestock distribution over the whole area. Reduction of AUMs in 
this step comprised the largest percentage of the overall reduction. 

Step III 

Erosion potential on certain soil types eliminated AUM recommenda- 
tions on those sites. These reductions were in addition to those in 
S t ep II. 

Step IV 

Evaluation of AUMs available after Step II in relation to various 
wildlife objectives was the final step of the forage allocation process. 
Small reductions, based on Habitat Evaluation Procedures, were made to 
ensure forage for big game or residual cover for other wildlife species 
on a site specific basis. 

The following is a hypothetical example of Step I through Step IV 
on a single refuge section. 

Section Six AUMs Available to Livestock 


Step I Range Site and Condition Survey 

Range Site A, excellent condition 
Range Site B, good condition 
Range Site C, fair condition 

subtotal 


50 

30 

20 

100 


total 100 


Step II Slope/water matrix 
Range Site A 
Range Site B 
Range Site C 



-20 



-15 



-15 


subtotal 

-50 

total 


216 


Appendix 15. (Cont’d.) 


Step III Erosion hazards 


Range Site A 
Range Site B 
Range Site C 


-0 

-7 

subtotal -7 total 43 


Step IV Wildlife objectives 
Range Site A 
Range Site B 
Range Site C 


-5 

-0 

subtotal -5 total 38 


AUMs available to livestock on section six total 38. 

Detailed Analysis 

The AUMs derived from the standard SCS range site and condition 
survey (see Appendix 8) were considered as a beginning level and the 
first step in allocation of forage on the refuge. 

Mackie's work (1970) on mule deer, elk, and cattle interrelation- 
ships provided much of the basis for allocating forage to wildlife and 
livestock on the refuge. The study took place on lands included within 
or bordering the refuge on its southwest boundary during 1960-64. 
Observations of elk, deer, and cattle were made during all four seasons 
throughout the study period by activity such as feeding, bedding, or 
loafing, standing alert or traveling, occurrence on various habitat 
types, slopes, exposures, distances from water, and locations when first 
seen. A total of 11,581 observations of mule deer, 3,489 of elk and 
25,107 of cattle were recorded during the study. Additionally, a simi- 
lar study was made by Knowles (1975) on the north side of the Missouri 
River in the Nichols Coulee area and provides additional supportive 
information. 

Information obtained by Mackie and Knowles was used to determine 
primary use areas for livestock and develop slope and water criteria. 
These criteria were used to make adjustments to the interim AUM level 
derived from the recommended stocking rates provided in SCS stocking 
guides. The objective in making slope and water adjustments was to 
provide a basis for stocking key livestock areas at a proper stocking 
rate. This would mean that more inaccessible areas which are seldom 
grazed by livestock would not be allocated on an across-the-board stock- 
ing rate basis in accordance with the grazing guides. Such a situation 
appears to have prevailed during the 1952-53 range survey, which set 
stocking rates maintained to the present time. 

Primary livestock areas according to Mackie would include exten- 
sive, unbroken ridge tops and broad coulee bottoms within a mile of 
dependable water. Primary mule deer areas included moderate to steep 
slopes in the ponderosa pine-juniper habitat type and the big sage- 
bluebunch wheatgrass habitat type on smaller ridgetops and along margins 


217 


Appendix 15 


Appendix 15. (Cont’d.) 

of more extensive ridges. Small to moderately extensive ridgetops 
dominated by the latter type in areas of light cattle use were appar- 
ent primary range areas for elk. Unlike cattle, Mackie felt that deer 
and elk were somewhat slope and water independent and that essentially 
all the wildlife refuge was available for their use. R. Ross (personal 
communication) indicated that large coulee bottoms and extensive ridge- 
tops were primary livestock areas with the rougher, broken country 
better suited for wildlife. 

Mackie’ s work provided that, ’’Management programs, numbers, and 
management of livestock should be considered on the basis of forage 
available on primary range areas rather than on types of the entire 
area." In recognition of this statement, a slope-water matrix for 
livestock was developed using Mackie’s criteria as the basis for allo- 
cating forage to livestock. Livestock would be allocated forage based 
upon recorded on-site observations of use and distribution. This would 
result in a proper stocking rate for the primary areas where cattle tend 
to congregate. A maximum livestock stocking rate was therefore deter- 
mined using the slope-water criteria provided in Mackie’s study. CMR 
was created for the primary benefit of wildlife with excess forage to be 
allocated to livestock. All AUMs within a section recommended by the 
SCS stocking guides may be made available for wildlife if key or criti- 
cal habitat is present to justify such an allocation. Conversely, all 
the AUMs may be allocated to livestock if there are no wildlife needs. 

The slope-water matrix is provided in Appendix Table 15a. Slope 
and water criteria are based upon actual observations of livestock 
during Mackie’s study. The basis for the availability coefficient was 
determined with J. Nelson (personal communication). Nelson verified 
that the slope-water matrix was a reasonable model from which to derive 
information. Mackie reported that 82 percent of his total livestock 
observations were on slopes of 0-10 degrees, 13 percent 11-25 degrees, 4 
percent 25-36 degrees and trace amounts over 35 degrees. His breakdowns 
by distance from water were: 

Distance Percent observations 

0 - 1/4 37 

1/4 - 1/2 22 

1/2 - 3/4 20 

3/4 - 1 11 

1-2 10 

A total of 90 percent of all observations of livestock was within 
one mile or less of water. 

Availability coefficients were then determined by slope and water 
observation percentages for each slope category and distance factor for 
livestock. For example, slopes of 0-10 degrees were considered non- 
limiting for livestock, as were distances of 0-1/4 miles from water. 

The availability coefficient would be 1.00 or 100 percent of the total 
AUMs available to livestock. Since 82 percent of all observations were 
on slopes of 0-10 degrees, 18 percent would have occurred on slopes of 
greater than 11 degrees. Although 13 percent of the observations oc- 
curred on slopes of 11-25 degrees, the figure used for the 11-25 degree 


218 


Appendix 15. (Cont’d.) 


Appendix Table 15a. Slope-water matrix for livestock on the Charles 
M. Russell National Wildlife Refuge, Montana. 


Degree of 
slope 

Slope 

coefficient 

Distance to 
water (miles) 

Water 

coefficient 

Availability 

coefficient 

0-10 

1.0 

0 - k 

1.0 

1.0 

11 - 25 

0.18 

0 - v 4 

1.0 

0.18 

26 - 35 

0.05 

o - k 

1.0 

0.05 

35 + 

0.01 

o - k 

1.0 

0.01 

0-10 

1.0 

k - k 

0.63 

0.63 

11 - 25 

0.18 

— 'i 

0.63 

0.11 

26 - 35 

0.05 

"£ i2 

0.63 

0.03 

35 + 

0.01 

k-k 

0.63 

0.01 

0-10 

1.0 

h - 3/4 

0.41 

0.41 

11 - 25 

0.18 

k - 3/4 

0.41 

0.07 

26 - 35 

0.05 

k - 3/4 

0.41 

0.02 

35 + 

0.01 

*5 - 3/4 

0.41 

unsuitable 

0-10 

1.0 

3/4 - 1 

0.21 

0.21 

11 - 25 

0.18 

3/4 - 1 

0.21 

0.04 

26 - 35 

0.05 

3/4 - 1 

0.21 

0.01 

35 + 

0.01 

3/4 - 1 

0.21 

unsuitable 

0-10 

1.0 

1-2 

0.10 

0.10 

11 - 25 

0.18 

1-2 

0.10 

0.02 

26 - 35 

0.05 

1 - 2 

0.10 

unsuitable 

35 + 

0.01 

1-2 

0.10 

unsuitab le 


219 


Appendix 15 


Appendix 15. (Cont’d.) 

category was 0.18; 18 percent of the total observations occurred on 
slopes steeper than 11 degrees, and it was concluded that 5 percent 
differential use on slopes of 26-35+ degrees could just as likely occur 
on the 11-25 degree slopes. 

Slope gradients for each section were determined by means of aerial 
photo interpretation and use of topographic maps with contour intervals. 
Slope gradients for each category on the slope-water matrix were measured 
and determined for each range site and tallied with water criteria to 
get acreages by each slope and water class. The availability coeffi- 
cient (see Appendix Table 15a) was then applied to the interim AUM 
figure derived from the range site and condition survey for each parti- 
cular range site. This process determined a maximum recommended live- 
stock stocking guide based upon the slope-water matrix. 

Distances to known water sources were obtained from questionnaires 
received from livestock permittees, information provided by FWS field 
personnel, and locations of wells, ponds, and springs shown on topo- 
graphic maps and range survey aerial photos. Named creeks appearing on 
Geological Survey topographic maps as either permanent or seasonal 
streams were considered to be reliable water sources unless information 
provided by field personnel indicated that the source was not utilized 
by livestock. 

In examining range sites which would be considered to be key cattle 
areas, the following sites would be most important in terms of forage 
production and suitability: 


1 . 

overflow 



2. 

sandy 



3. 

silty 



4. 

clay 



5. 

thin hilly (0-10 degree slopes) 



6 . 

shallow clay (0-10 degree slopes) 



7. 

panspots 



8. 

dense clay 



Present key deer and elk use areas would include the 

following 

sites : 




1 . 

clay (areas of light cattle use) 



2. 

thin hilly 



3. 

shallow clay 



4. 

panspots (areas of light cattle use) 


5. 

dense clay (areas of light cattle 

use) 


6 . 

shallow clay-shale complex 



7. 

thin breaks 



8. 

shale 



Areas which may assume key importance 

for pronghorns, 

elk, and 

for short periods may include: 



1 . 

saline lowland (emergency food) 



2. 

thin breaks (security cover) 



3. 

saline upland (emergency food) 



4. 

badlands (security cover) 




220 


Appendix 15. (Cont'd.) 

An attempt to quantify all criteria influencing distribution and 
use of forage by livestock and wildlife in terms of a mathematical 
equation is not easy. Other factors such as age class and breed of 
cattle may affect distribution patterns considerably. Yearlings are 
especially prone to be more slope and water independent than mature 
animals. Season of use may affect distribution patterns somewhat with 
animals tending to concentrate near water in hot weather and to range 
further from water during cooler fall weather. Information in present 
range publications indicates that the slope-water criteria presented 
above is comparable with data from other areas. The Forest Service 
(1964) indicated studies in the Stansbury Mountains in Utah revealed 
that most of the range classed as suitable was on slopes of 5-18 per- 
cent. Julander and Jeffrey (1964) found that cattle in Utah made little 
use of slopes greater than 30 percent, restricting most of their use to 
slopes of less than 10 percent. In Montana, Mueggler (1965) found that 
areas 200 yards up 30 or 60 percent slopes are occupied only 20 and 11 
percent respectively as much as areas at the bottom. Slopes greater 
than 50 percent are generally considered unsuitable for livestock graz- 
ing (Bureau of Land Management 1976). 

In regard to water, Skovlin (1965) indicated that cattle will 
seldom graze more than 1/2 mile from water where slopes are in excess of 
40 percent. The Forest Service agrees that cattle should not be forced 
to go over 1/2 mile from water in rough terrain or forced to go more 
than 2^ miles even on level terrain. Skovlin indicated cattle could 
travel up to 3 miles for water on gentle ground but would not be found 
that far away in summertime unless forage was gone for some distance 
about the water supply. 

Soils limitations in the form of insufficient vegetation or erosive 
hazard provided a final consideration for AUM allocations. W. Larsen 
(personal communication) revealed certain soils mapping units which 
should be excluded from grazing. These mapping units were excluded from 
the AUM allocations during final compilations. 

The fourth and final step in livestock AUM calculation was review- 
ing AUM recommendations to this point in light of the area's wildlife 
objectives. Where Habitat Evaluation Procedures data (see Appendix 2) 
suggested an additional need, further reductions were made for big game 
forage or residual cover for sharp-tailed grouse and other wildlife 
species . 

In the final analysis it must be remembered that the range site and 
condition inventory as presented in the SCS National Range Handbook is 
primarily a livestock-oriented inventory tool. As such, it has limi- 
tations when applied to wildlife needs. Animals such as elk, which have 
diets similar to cattle, can be considered along the same basic lines 
when it comes to allocating forage. Other needs such as security cover 
and interspers ion of habitat needs are not so clear cut nor are the 
needs of deer and pronghorns or other less obvious wildlife species. 
However, it serves an important function as a management tool because it 
expresses present vegetation in terms of its potential climax. By 
examining what is present on the site and knowing wildlife needs for 
that site, a decision can be made as to the treatment to be employed to 
obtain the desired result. 


221 


Appendix 16 


Appendix 16. Literature review for Charles M. Russell National 
Wildlife Refuge, Montana, range survey and wildlife-livestock 
interrelationships . 

Consideration of interrelationships between livestock and wildlife 
is the basis for making recommendations for the benefit of all wildlife 
species on CMR. Such interrelationships have been much discussed by 
wildlife managers. Whereas intensive livestock grazing may be detri- 
mental to wild ungulates, prescribed grazing treatments have been found 
to benefit other wildlife species. Complete elimination of livestock 
grazing on the refuge would eliminate a management tool the manager has 
at his disposal. 

Smith (197 7) stated, ''Livestock grazing is the single most impor- 
tant factor limiting wildlife production in the west. It has been and 
continues to be administered without adequate consideration for wild- 
life, especially on federally owned lands." Mackie (1978) reported that 
very few studies have been attempted in which more than a few of the 
possible effects and processes of competition and other grazing impacts 
have been considered. Most measure only short-term effects. More impor- 
tantly, few studies have ever attempted to compare behavior and perform- 
ance of wild ungulate populations between similar adjacent grazed and 
ungrazed ranges. Mackie (1978) stated that livestock grazing did not 
become established as an important factor until the mid-1880's, with the 
resulting disruption of habitat and interspecific relationships between 
grazing ungulates being of rather recent occurrence. Mayr (1963) ob- 
served that intense competition can occur when two species initially 
come into contact or where a radical change in the environment has upset 
a previous balance. Because of this rather recent introduction of 
domestic livestock onto western rangelands, changes have occurred in 
vegetative conditions and composition at an accelerated rate along with 
the adaptations by wildlife species to adjust to these rapidly changing 
conditions . 

Direct negative impacts resulting from livestock grazing cited by 
Mackie (1978) include direct competition for food, cover, and space. 

Food requirements may be nearly identical, as between cattle and elk for 
most of the year, or may overlap for only short, often critical periods 
such as between cattle and deer during early spring growth of grasses 
and forbs. As grazing pressure increases, there is a greater tendency 
for diet overlap to occur. Trampling becomes important with heavier 
livestock use. Pearson (1975) reported that direct forage consumption 
accounted for only 36-47 percent of the total herbage removed or lost 
where cattle are grazed with trampling accounting for the remainder. 

Season of use may affect livestock-wild ungulate interrelations 
according to Mackie (1978). Fall and spring range may be limited in 
extent; utilization by livestock of critical winter ranges after plant 
growth is completed may have an adverse impact. Alterations of cover by 
livestock may be a direct negative impact on wild ungulates when calving 
or fawning time occurs because of the tendency of these animals to have 
young in somewhat open, low shrub-grass cover types. Reductions or loss 
of cover could result in increased losses to predation or weather. 


222 


Appendix 16. (Cont’d.) 


Feeding behavior of wild ungulates may be greatly influenced by 
presence and grazing of livestock. McMahan (1964) observed that white- 
tailed deer used significantly more browse and generally more grass and 
less forbs on season-long livestock grazed pastures as compared with an 
ungrazed area. Knowles (1976) found heavier use of forbs, especially 
yellow sweet clover, by mule deer in an ungrazed pasture compared to a 
livestock grazed pasture where deer utilized more browse. Buechner 
(1950) reported that pronghorn diets may be greatly altered on over- 
grazed cattle range, while overgrazed sheep range is unsuitable for 
pronghorn use. Distribution and movements of mule deer and elk in 
northcentral Montana may be influenced by occurrence of livestock on 
rangelands (Knowles 1975, 1976). Komberec (1976), McMahan (1966), 
Ellisor (1969), Firebaugh (1969), Dusek (1971), and Hood and Inglis 
(1974) suggested that livestock may interfere with deer use of all 
available habitats and may exclude deer use from some areas. Move- 
ments of elk from areas used by livestock have been reported by Jeffrey 
(1963), Dalke et al. (1965), Stevens (1966), Skovlin et al. (1968), 
Mackie (1970), Stark (1972), and Lonner (1975). 

Mackie (1978) stated that indirect negative impacts by livestock 
on wildlife include gradual reductions in vigor of plants and quality of 
forage available, elimination or reduction in reproductive parts or 
vigor of plants such that future forage is diminished, elimination or 
reduction of important cover types and replacement by less favorable 
types, and alterations or reductions in the kinds, quality, or amounts 
of preferred plants through selective grazing. Where grazing is uniform 
or becomes so over large areas, vegetational diversity may be decreased. 

Some individuals believe that livestock grazing is inherently or 
largely detrimental to wild ungulates as a result of these long term 
influences. Gallizioli (1977) considered overgrazing by livestock to be 
a major factor in destruction of deer and other wildlife habitat in the 
southwest. Severson and Bolt (1978) indicated that heavy livestock 
grazing on the northern Great Plains appears to have been a major factor 
in reduction of deciduous trees and shrubs along drainage ways. Such 
cover types may be critical to mule deer and other wildlife species of 
the area. Mackie (1978) indicated that diversity of cover types may be 
important, if not essential to mule deer. Irregular or spotty heavy 
grazing by livestock earlier may have contributed to this situation. 

More uniform distribution resulting from more intensive grazing systems 
or improved water distribution could result in less desirable conditions 
for deer. 

The aspect of competition between wildlife and livestock was 
recognized by Smith and Julander (1953) as occurring in two forms - 
forage competition, which occurred if the supply of a forage species 
used in common was not adequate to meet both species’ requirements 
within proper use limits for the species, and land use competition which 
may occur even with adequate forage but where lesser usage by one 
species would allow greater usage or numbers of the other species to 
occur. Mackie (1976) pointed out that it is quite difficult to effec- 


223 


Appendix 16 


Appendix 16. (Cont’d.) 

lively evaluate range relationships, competition, and management needs 
of wild ungulates and other wildlife. He mentioned that he did not 
measure diet preferences but rather the response of deer and elk to 
livestock presence and grazing, noting that elk tended to avoid areas 
presently or previously grazed by cattle. He expressed interest in the 
potential of "social intolerance" as cited by Lonner (1975). Recent 
Missouri River breaks studies involving pastures where no livestock 
grazing occurred or on rested pastures in a rest-rotation system showed 
strong differences in wild ungulate distribution and use in relation to 
cattle distribution and use (Knowles 1975, Komberec 1976). Knowles 
(1975) observed that deer either moved or used all parts of their home 
range when cattle were turned into previously ungrazed pastures. Skovlin 
et al. (1968) reported that elk use was significantly less on range 
cohabitated with cattle than in areas where cattle use was restricted. 
Rates of elk use decreased as cattle stocking increased; however, moderate 
cattle stocking inhibited elk as much as heavy cattle stocking. 

Skovlin et al. (1968) concluded that a light stocking rate promoted 
maximum sustained use of forage for livestock and wildlife. Where live- 
stock production is the primary objective, moderate stocking would best 
fulfill the objective. Skovlin and Harris (1970) found that elk pre- 
ferred season-long cattle ranges to deferred rotation ranges when 
cattle stocking was light. However, elk preferred heavily stocked 
rotation ranges to heavily stocked season-long ranges. Nelson and 
Burnell (1975) evaluated elk-cattle competition on pastures in a ro- 
tational grazing system and found that cattle and elk interacted sig- 
nificantly for both forage and space. Distribution patterns showed 
moderate overlap, and diets overlapped significantly. Social inter- 
action between the two groups resulted in elk leaving the pasture to 
which cattle were moved, and elk were not observed to use the pasture 
used by cattle following cattle removal, except those areas within that 
pasture which were ungrazed by cattle. 

Range improvements such as fencing and water developments often 
result in better range management as a result of improved distribution, 
more uniform utilization of forage, and less damage to soil and range 
resources. Mackie (1978) pointed out that while this may benefit the 
range resource, effects on wild ungulates may be detrimental. Fences 
can interfere with migrations and access to habitats for wild animals. 
Direct mortality may also occur as a result of crossing fences. Papez 
(1976) found that 13 percent of 144 mule deer mortalities to factors 
other than hunting, crippling, and winter kill were fence kills. As in 
the case of fencing, Mackie (1978) stated that in the development of 
water, "The expected effect may be the opposite by extending livestock 
use generally to previously little or only seasonally grazed areas and 
habitat types such that overlap or opportunities for overlap in use of 
resource are increased. This may be true on long continuously grazed 
ranges or on seasonally grazed ranges where stocking rates may be high." 
Additionally, uniform grazing patterns may result in the adverse effect 
of decreasing vegetation diversity of an area. 


224 


Appendix 16. (Cont'd.) 


Effects of various grazing livestock systems upon wild ungulates 
has been discussed to some extent earlier in this section. Skovlin et 
al. (1968) observed deer and elk use on dual use livestock-big game 
ranges and single use big game-only ranges. Big game made the greatest 
use of range where cattle did not graze. Deer had a tendency to utilize 
the deferred rotation pastures more than the season-long pastures. No 
significant use difference was found between single and dual-use pas- 
tures for deer or for the three stocking levels on the dual-use pas- 
tures. Elk, however, utilized the game-only pastures at a significantly 
higher level than on dual-use pastures. As cattle stocking increased on 
the dual-use ranges, elk use decreased significantly, apparently because 
of greater abundance of ungrazed forage in the deferred units. Under 
light stocking, elk preferred season-long pastures, but under heavy 
stocking they preferred rotation pastures. As mentioned previously, 
light stocking was found to be the most desirable system. 

Knowles (1975) found that in a rest-rotation grazing system in the 
Missouri Breaks, mule deer distribution and movements appeared to be 
affected by grazing treatments, and fawn production and survival may 
have been depressed in pastures receiving heavy grazing. Elk responded 
to the grazing by moving from grazed to ungrazed pastures without appar- 
ent effect. Heavy grazing use such as might be found on rest-rotation 
system grazed pastures leaves little residual vegetation and may in- 
crease the vulnerability of young animals to predation. Populations of 
microtine rodents may be reduced, forcing predators to seek alternate 
food sources, including wild ungulates. 

Wittinger (1978) indicated that the dietary overlap between elk and 
deer was significant on rest-rotation pastures in Idaho. However, elk 
moved out of areas used by cattle, which lessened direct competition for 
forage but also limited the range area available to elk. No adverse 
effects on the elk population were noted during the study as a result of 
this situation. 

Anderson and Scherzinger (1974) reported on a rest-rotation grazing 
system to improve winter elk forage in Oregon. Cattle were moved onto 
the range following range readiness and moved off the range at the 
midpoint of the growing season. The regrowth was then made available to 
wintering elk in the area. This sytem resulted in an increase in live- 
stock forage because of improved range condition and an increase in elk 
use as a result of regrowth of high quality winter feed. 

Mackie (1978) indicated that the often overlooked area of inter- 
specific competition between wild ungulates may be intensified by live- 
stock use. Elk tend to overlap both cattle and deer somewhat in terms 
of diet and distribution. Elk also tend to avoid cattle or areas 
grazed by cattle whenever possible. Areas not accessible to cattle are 
often highly important deer habitat areas. This tends to intensify 
competition between elk and deer. Changes in livestock practices may 
affect deer-elk relations in addition to deer-cattle and elk-cattle. 

Beneficial impacts may result from dual use of rangeland by domes- 
tic livestock and wild ungulates. Use by livestock may result in 


225 


Appendix 16 


Appendix 16. (Cont'd.) 

greater diversity in the habitat, thus indirectly benefitting certain 
wildlife species. Overgrazing of many intermountain ranges ultimately 
benefited deer populations by allowing browse species to invade lands 
formerly occupied by grasses. Mackie (1978) stated that while heavy or 
abusive grazing during one season may be destructive to wild ungulate 
habitat values, lighter grazing or grazing at another season may in- 
crease the availability of plants or have other beneficial habitat 
impacts. Mackie indicated that while a livestock grazing impact may 
benefit one species, it may detrimentally affect another. Longhurst et 
al . (1968, 1976) indicated that retrogressive succession from grasses 
and forbs to browse may have eliminated bighorn sheep while benefitting 
mule deer. Cosby (1978) reported that a planned livestock grazing sys- 
tem benefits both wildlife and the range in addition to providing 
livestock forage. Cosby recommended a rotation deferred grazing system 
to improve wildlife conditions. He mentioned a case of rotation by deer 
that coincides with livestock, where deer follow cattle to make use of 
succulent regrowth. 

Anderson and Scherzinger (1974) indicated that elk habitat of the 
Bridge Creek Wildlife Management Area in Oregon was improved by imple- 
mentation of a planned grazing program for livestock as well as improve- 
ment of range conditions. Elk made use of the regrowth on the management 
area following livestock removal. Cattle grazing was heavy enough to 
"top-off" grazed pastures, but light enough to leave an adequate volume 
of forage for elk in all pastures following livestock removal. 

Mackie (1978) concluded one report with the observation that the 
probability of conflict between wild ungulates and livestock is high, 
and some negative impacts may be inescapable whenever livestock grazing 
occurs on range occupied by wild ungulates. He indicated that infor- 
mation is lacking with respect to impacts of grazing on wild ungulates. 
However, he cited numerous studies that have occurred in Montana and 
other western states which indicate that livestock grazing is detri- 
mental to deer and elk. One study on nine state game ranges in Montana 
revealed that wintering elk numbers have increased an average of at 
least 100 percent following livestock removal. 

Analysis of effects of livestock grazing upon ground nesting birds 
generally reveals that diversity of species and nesting densities are 
higher in undisturbed habitats than where grazing is allowed (Kirsch 
1969) . Quantity and quality of cover generally are adversely affected 
by grazing and trampling which affect density of nests and may affect 
nesting success because of predation on areas having reduced cover 
(Creston Valley Wildlife Management Authority 1974). Certain species 
such as the prairie horned lark, western meadowlark, and mountain plover 
benefit from moderate grazing intensities, however (Smith 1940, Karuziak 
et al. 1977). 

Sisson (1976) indicated that sharp-tailed grouse in Nebraska 
preferred climax vegetation sites having relatively open canopy and 
sparse current growth with accumulation of plant litter. This probably 


226 


Appendix 16. (Cont'd.) 


indicated avoidance of cool season grasses and forbs as well as a 
preference for residual cover of warm season grasses. Accumulation of 
litter on favored sites was attributed to very light or no livestock 
grazing. Christenson (1971) concluded that uniform stands of vegetation 
at least 12 inches high or patches of vegetation at least 14 inches high 
were necessary for nesting. He proposed that regulation of grazing to 
maintain uniform stands of vegetation at least 12 inches high might 
substantially increase grouse populations. Sisson’s conclusions in his 
report were that grouse requirements differ from those considered desirable 
from a livestock production standpoint. Int erspers ion of cover and habi- 
tat diversity are generally reduced by high intensity grazing systems. 
Sisson stated that diversity of vegetation resulting from selective 
grazing (as opposed to planned, high intensity grazing systems) by 
livestock and wild herbivores would be expected to contribute to long 
term stability and productivity of the system. This concept should be 
carefully considered in evaluating impacts of this type system versus 
intensive grazing systems. 

Effects of grazing upon small mammals may vary by species and 
grazing intensity. Flinders and Hansen (1975) reported that black- 
tailed jackrabbits were most abundant on light to moderately grazed 
ranges. Turner (1969) reported that pocket gopher activities appeared 
greater on ungrazed than grazed ranges. Cover is essential to sage vole 
survival, whether it be growing or litter. According to Maser (1972), 
cover provides some needed protection from predators for small mammals 
which are active during daylight. Deer mice, being nocturnal, are not 
so limited by cover limitations. Other small mammals such as prairie 
dogs appear to thrive in areas which have been abused in the past. Once 
the tall perennial grasses have been removed, prairie dogs are able to 
maintain a lowered state of plant productivity and site quality through 
colonial activities. 

In summary, an examination of the available literature reveals only 
few situations in which livestock grazing benefits wildlife. Deer and 
small mammal populations have often responded dramatically to range 
overuse which replaces climax species with those more palatable or 
conducive to populations of the benefitting wildlife species. In 
certain situations, removal of old, cured vegetation will make plant 
regrowth more palatable to wildlife species. Removal of excess, old 
forage will also allow establishment of new individual plants, thus 
improving range and watershed conditions. A look at the wildlife 
species priority list under which proposed management priorities will be 
developed for CMR reveals that mule deer, sharp-tailed grouse, and elk 
will be the species having the greatest importance in terms of manage- 
ment impacts. All three species are affected to varying degrees by 
livestock grazing. 

An analysis of the available literature concerning livestock- 
wildlife interrelationships results in the following conclusions: 

1. Grazing by livestock has relatively few beneficial impacts upon 
wildlife . 


227 


Appendix 16 


Appendix 16. (Cont’d.) 

2. Under light grazing intensities, livestock grazing is probably 
a "no-harm, no-good" situation in relation to most wildlife populations. 
Interspers ion of habitat conditions which may result from light, selec- 
tive livestock grazing may enhance certain wildlife species which re- 
quire a vegetative mosaic for optimal habitat conditions. 

3. Moderate and heavy livestock grazing intensities provide ever 
increasing detrimental effects upon most wildlife species. Certain 
species such as prairie dogs and mule deer may be positively affected by 
range overuse. Moderate livestock grazing rates would apply where 
wildlife values are not to be considered the major or dominant use. 

4. Under light livestock grazing intensities, seasonal grazing 
appears to provide the best answer for CMR. Such a system should 
result in livestock activities being primarily confined to major coulee 
bottoms and ridge tops of gentle relief. Light stocking rates would help 
provide proper use of such areas; the majority of the refuge, which 
contains steeper topography, would be reserved for wildlife use. 

5. Under moderate grazing intensities, implementation of an 
intensive grazing system such as rest-rotation would appear to offer the 
best solution for wildlife populations. A three or four pasture rest- 
rotation system would provide sanctuary for wildlife on the rested pas- 
tures when livestock are present on the pasture to be grazed. Such a 
system would require development of additional water facilities and more 
fencing, both of which may be detrimental to wildlife. Water develop- 
ment allows better distribution of cattle and allows them to penetrate 
sanctuaries formerly reserved for wildlife. Fencing impedes wildlife 
movements. If the decision is made to implement such a system, the 
"stocking rate is based on the forage that is produced on the portion of 
the range that is open for use each year" (Hormay 1970) . Moderate 
grazing intensities should be applied where multiple use concepts are to 
be employed. 

6. Livestock grazing should be regarded as a management tool to 
enhance wildlife populations. Flexibility should be an inherent part 
of the system; numbers should be modified in part by forage production 
during a given year. Introduction of heavier than normal livestock 
numbers temporarily into a pasture to remove rank vegetation could also 
be a management objective. 

The feeling as to reasons why a wildlife refuge should contain 
domestic livestock is perhaps best summarized by Murie (1935): "I might 
mention that cattle here and there, if not so numerous that one is 
apprehensive about the range, also fit into the picture. There is 
something picturesque about the old time cattle ranch, although the 
outdoorsmen would not like to have that feature to pervade the entire 
field. Simplicity on a grand scale is the keynote of this whole outdoor 
picture. " 


228 


Appendix 17. Methodology for estimating visitor use on the Charles M. 
Russell National Wildlife Refuge, Montana. 

Although estimates of visitor use on the refuge have been made in 
the past, reliability of this information is tempered by a number of 
variables. The refuge is accessible by road, trail, horseback, foot, 
water, or other means at many locations. Only in a few areas is access 
controllable, such as at developed recreation areas. Thus, it is almost 
impossible to sample the many access routes and determine the amount of 
use the area receives. This is further complicated by the fact that 
three major highways cross the refuge: State Highways 24 and 117 on the 

east, and US Highway 191 on the west. 

For purposes of this study, total visitation was estimated for 
dispersed recreation areas, developed recreation areas, and the Upper 
Missouri National Wild and Scenic River. Dispersed recreation areas 
constitute the bulk of undeveloped land and water surface on the refuge, 
as contrasted to developed recreation areas administered by COE and 
MDFW&P. The nationally designated wild and scenic river segment at the 
west end of the refuge is administered by BLM. 

Dispersed area visitation 

Dispersed areas were divided by the level of use they receive: 
high, medium, or low. These areas were determined by traffic count 
data, field observations, and professional judgment. Traffic count 
data were only available for a three-month period during the summer 
involving four traffic counters. Reductions were made in total counts 
to compensate for traffic not directly involved in recreation. Visita- 
tion for each type of area was calculated with these data, assuming that 
the amount of use they receive is in proportion to the volume of traffic 
on major highways crossing the refuge. 

Participation rate factors derived from a preliminary survey of 
recreation use on the refuge (Fish and Wildlife Service 1978) were then 
applied to the estimate of visitors on dispersed use areas to obtain a 
measure of current visitation by activity (activity days). Based on 
survey data, activity days were converted to recreation days using a 
factor of 3.8, which represents the average number of activities in 
which an individual participates while visiting the refuge. Recreation 
days were then divided in half to obtain the number of visitor days, 
since a visitor day is half as long as a recreation day. 

Since the year in which the previously referenced visitor survey 
was conducted was atypical due to bad weather, which restricted access 
by sportsmen, hunting and fishing use estimates were related to the 
Montana Statewide Comprehensive Outdoor Recreation Plan (Montana De- 
partment of Fish and Game 1978) for State Planning Regions 4, 6, and 7. 

Developed area visitation 

Since only partial information was available from COE on amount of 
visitation at developed recreation areas, it was necessary to estimate 


229 


Appendix 17 


Appendix 17. (Cont'd.) 

use at these areas. In calculating this visitation, a distinction was 
made between nearby recreation areas and outlying recreation areas. The 
primary difference between these two types relates to proximity of the 
areas to local service establishments. Nearby areas are those located 
close to the town of Fort Peck, where there are a number of opportuni- 
ties to obtain food, lodging, entertainment, and related services. In 
contrast, outlying areas are from 10-40 miles or more from the nearest 
service facilities. 

Using traffic count data compiled by COE (R. King personal com- 
munication), the number of total counts recorded at nearby and outlying 
areas was determined. It was estimated that a visitor to nearby areas 
would make an average of six trips to and from local service facilities 
during his stay, while those who visit outlying areas would make a 
minimum of two trips during their stay. 

Dividing traffic count data for nearby and outlying areas by the 
average number of trips made in and out by each vehicle provided an 
estimate of the number of vehicles at COE and State facilities. Mul- 
tiplying the resulting figure times 2.68, which represents the average 
number of people/vehicle (Fish and Wildlife Service 1978), yielded an 
approximation of the number of visitors. As with dispersed areas, 
participation rate factors were applied to this visitation to obtain 
estimates of use by activity and then converted to visitor days. 

Wild and Scenic River visitation 


Based on BLM data (W. Cutler personal communication), it was assumed 
that about 30 percent of the floaters on the Upper Missouri National 
Wild and Scenic River traverse that portion of the river through the 
refuge during the primary use season. River use during the balance of 
the year is unknown but thought to be minor. 

Projections of visitation 

Due to growing scarcity and rising cost of fuel for transportation 
as well as numerous competing recreation resources available outside 
CMR, the impact of recreationists on the refuge in future years was 
assumed to be primarily dependent on local and regional changes in 
population. Thus, estimates of future use on the refuge under the 
Proposed Action alternative were based on anticipated population in- 
creases in the 150-mile area immediately surrounding the refuge (Appen- 
dix Table 17a.) Anticipated visitation under the other alternatives 
was based on variation in facilities and opportunities that would be 
provided by each. It was assumed that this use would be divided between 
dispersed areas, developed areas, and the wild river in about the same 
proportion as 1978. 


2 30 


Appendix TabJe 17 a. Recreation visitation projections under each management alternative Tor the Charles M. Russell National Wildlife 
Refuge, Montana. 


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*l,esH than 1,000 visitor (lays 



VIII. GLOSSARY 








Glossary 


VIII. GLOSSARY 


ALLOTMENT. An area designated for use of a prescribed number and 
kind of livestock under a plan of management. 

ANIMAL-UNIT MONTH (AUM) . The amount of feed or forage required by 
an animal-unit for one month (approximately 1,000 pounds of air 
dry forage) . 

CARRYING CAPACITY. The maximum number of animals an area can support 
without inducing damage to vegetation or related resources. It may 
vary from year to year on the same area due to fluctuating forage 
product ion. 

CLASS OF LIVESTOCK. Age, sex-group, or species of livestock. 

COMMON ALLOTMENT. An allotment upon which several permittees graze 
livestock in common. 

CONTINUOUS GRAZING. The grazing of a specific unit by livestock 
throughout the year or for that part of the year during which 
grazing is feasible. The term is not necessarily synonymous 
with yearlong grazing. 

CROSS-FOSTERING. Putting eggs or young of one species of bird into 
the nest of a second species to be raised by the adopting parents. 

DANCING GROUND. A traditional gathering site where the courtship 
ritual between male and female sharp-tailed grouse occurs. Nest- 
ing and rearing areas are almost always close by. 

DIRECT ECONOMIC EFFECT. Income generated only by the economic sector 
(such as the livestock industry) to which a reference is made. 

DISCOUNTED. Brought back to a present equivalent value, interest 
rate used was 7 1/8 percent. 

DISPERSED RECREATION USE. Scattered recreation activity that occurs 
away from developed recreation areas. 

DNC. Cover such as a mix of legumes and grasses used by waterfowl 
for nesting. 

ECOTONE. A transition area of vegetation between two communities, 
having characteristics of both kinds of neighboring vegetation 
as well as characteristics of its own. Varies in width depending 
on site and climatic factors. 

EDGE EFFECT. The influence of one adjoining plant community upon the 
margin of another affecting the composition and density of the 
population of plants and animals. 


232 


EMERGENT. Rooted vegetation which grows above the surface of the 
water. 

ENDANGERED SPECIES. Any species which is in danger of extinction 
throughout all or a significant portion of its range. 

FALL STAGING AREA. An area where a number of individual animals of 
a species temporarily congregate in late fall before snow, ice, 
and cold weather forces them to winter habitat. During mild winters, 
wildlife may stay in staging areas the entire season. 

HEAVY GRAZING. More than 50 percent utilization of annual available 
forage . 

HEDGED CONDITION. Shrubs which resemble trimmed hedges, usually 
because of browsing by herbivores. 

INDIRECT ECONOMIC EFFECT. Income produced in one or more economic 
sectors (such as retail trade) by the receipt of income in another 
economic sector (such as the livestock industry) . 

LIGHT GRAZING. Between 0-35 percent utilization of annual available 
forage . 

LITTORAL. Shore zone between high and low water marks characterized 
by vegetation development which is used for stabilization of the 
shoreline and spawning for various fish species. 

MODERATE GRAZING. Between 35-50 percent utilization of annual avail- 
able forage. 

NATIONAL NATURAL LANDMARK. An area that possesses exceptional value 
or quality in illustrating or interpreting the national heritage 
of our nation. 

NATIONAL REGISTER OF HISTORIC PLACES. The official list of the nation's 
cultural resources worthy of preservation. 

NATURAL AREA. An area set aside indefinitely to preserve a represen- 
tative unit of a major forest, grassland, or wetland type primarily 
for the purposes of science, research, or education. 

PARENT MATERIAL. Unconsolidated mineral or organic matter from which 
soils are developed. 

PRESENT VALUE. An amount of money which will become a given amount at 
a stated time in the future. For example, at 10 percent interest 
$100 will grow to $110 in one year; therefore, the present value of 
$110 one year from now at 10 percent interest is $100. If the end 
product is a series of payments, the present value is the amount 
that will result in the sums of that series. 


233 


Glossary 


RANGE IMPROVEMENT. 1) Any structure or excavation to facilitate man- 
agement of range or livestock. 2) Any practice designed to improve 
range condition or facilitate more efficient utilization of the 
range. 3) An increase in the grazing capacity of range, i.e., 
improvement in range condition. 

RANGE READINESS. The defined stage of plant growth at which grazing may 
begin under a specific management plan without permanent damage to 
vegetation or soil. Usually applied to seasonal range. 

RANGE SITE. A distinctive kind of rangeland, which in the absence of 
abnormal disturbance and physical site deterioration, has the poten- 
tial to support a native plant community typified by an association 
of species different from that of other sites. This differentiation 
is based upon significant differences in kind or proportion of species, 
or total productivity. 

RESEARCH NATURAL AREA. An area on which natural features and processes 
are preserved with minimal human intervention for research and edu- 
cational purposes. This designation differs from other classifica- 
tions such as wilderness or refuge, in that the latter designations 
often have broader use-management objectives than the preservation/ 
scientific applications of the research natural area. 

RESIDUAL COVER. Vegetation, primarily grasses of sufficient height 
and density to hide birds from view at a level of three feet above 
the ground. 

RIPPING (RANGE). The mechanical penetration and shearing of range 

soils to depths of 8 to 18 inches for the purpose of breaking hard- 
pan layers to facilitate penetration of plant roots, water, organic 
matter, and nutrients. A range improvement practice used where 
native grasses of a rhizomatous nature can spread into the ripped 
soil . 

ROTATION GRAZING. System of pasture utilization embracing short periods 
of grazing followed by periods of rest for herbage recovery during 
the same season. Variations of rotation grazing include deferred 
rotation and rest-rotation systems. 

SECTION 7 CONSULTATION. Consultation with personnel of the U.S. Fish 
and Wildlife Service to determine environmental effects on species 
listed as endangered or threatened under Section 7 of the Endangered 
Species Act. 

SELF-FURNISHED AUMs. Livestock AUMs which are derived from privately 
owned or state leased land within the CMR boundary. The number of 
AUMs authorized is generally reflected on the grazing permit, but 
no fee is assessed by FWS for grazing. 


234 


STRUTTING GROUND. A traditional gathering site where the courtship 
ritual between male and female sage grouse occurs. Nesting and 
rearing areas are almost always close by. 

THREATENED SPECIES. Any species which is likely to become an endangered 
species within the foreseeable future throughout all or a significant 
portion of its range. 

VISITOR CONTACT CENTER (VCC) . A manned facility designed to provide 
general information. 

VISITOR CONTACT STATION (VCS) . An unmanned facility designed for 
dispersing information. 

VISITOR DAY. Participation by an individual in one or more recreation 
activities during all or part of a 12-hour period. 

VISITOR INTERPRETIVE CENTER (VIC). A structure designed for full-scale 
interpretation using exhibits, displays, and other media. 

WILDERNESS. An area which has not been seriously altered by man set 
aside by legislative action to preserve a representative unit of a 
major forest, grassland, or other land classification type. 


235 


IX. INDEX FOR TEXT 






IX. INDEX FOR TEXT 


A 

Access, 8,13,14,16,20, 

27,50,52,67,78,89,93,94 
Activities (see recreation 
activities) 

Aerial surveys (see surveys) 
Aircraft landings, 13,16,78 
Animal damage control (ADC) , 
7,12,19,21,24,25, 

65.71.84.90.91.100 
Aridisols (see soils) 

Assumptions, 61 

B 

Backcountry (nonmotorized) 
trail (see trails) 

Big sage-greasewood-grassland, 
5,21,39,73 

Bison grazing (see grazing) 

Brood (see ponds) 

Burning (see fire management) 

C 

Canoe trail (see trails) 

Climate, 33 

Climax vegetation, 41,85, 

99.100 

CMR goals (see goals) 

Constraints, 9,11,16,17,26 
Continuous grazing (see 
grazing) 

Competing recreation resources, 

50 

Competition (see livestock- 
wildlife interrelationships) 
Crop depredations, 5,11,44 
Cross-fostering, 49 
Cultivated land, 39,41 
Cultural resources, 3,4,6,8,13- 
16,20,22,25,27,50,61,67,77, 

86,87,93,100,101 
archeological, 67,77 
historical, 14,22,67,77,86 
paleontological, 67,77 

D 

Deferred-rotation system 
(see grazing systems) 

Direct economic effects, 67,68,78, 
79,87,94,101,103 
Domestic sheep, 11,72 


E 

Early spring use (see grazing) 
Ecotone, 49 

Endangered species, 4,7, 
10,18,21,33,50,77 
Energy resources, 36,57 
Entisols (see soils) 

Environmental education study 
areas, 4,6,14 

Emergent vegetation, 41,90 
Executive orders, 9,16,24,26,31 

F 

Farming, 7,9,11,16,19,21,24 
26,55,57,73,83 

Fire management, 3,11,19,21,63, 
70,81,89,97,99 
wildfire, 7,11,19,21,63, 

70,81,97 

prescribed burns, 7,10, 

11,18,19,21,24,73,82,84,85,91, 

94,99,101 

Fisheries (resource & management), 
7,12,13,19,21,24,45,74,84,91 
Fishing, 4,6,8,9,12,52 
Forage allocations, 7,12,19,21,24, 

26,65,67,74,77,81,84,91,94,97,101 
Fort Peck Dam, 13,26,31,34,38 

G 

Geology, 34 
Goals (CMR), 4,9 
Grazing (see also): 

bison grazing, 75,85 
continuous grazing, 9,12,26,42, 

74.76.90.92 

early spring use, 12,13,66 
heavy grazing, 66,84 
light grazing, 9,12,72 
75,76 

livestock grazing, 7,9,12, 
16,18,19,90 

moderate grazing, 19,72,75 
84 

no grazing areas, 16,17,21 
prescription grazing, 10, 
12,18,21,72,73,74,76,82, 

84,85,100 

seasonal grazing, 9,12,26, 

42.74.90.92 

yearlong grazing, 42,66,74 


236 


Grazing allotments, 12,42, 

57,92 

Grazing systems 

deferred-rotation, 12,13, 
22,42,91,92 

rest-rotation, 12,13,22 
42,89,91,92,100 

H 

Habitat evaluation procedures, 

10 (HEP) (see also surveys) 
Habitat treatments 

cooperative farming (see farm- 
ing) 

exclosure construction, 
11,19,21,24,70,73,76 

81.83.97.99 

livestock grazing (see graz- 
ing) 

prescribed burn (see pre- 
scribed burns under fire 
management 
ripping, 9,10,11, 

13,20,22,25,70,76,77,81, 

85,86,89,92,94,97,100,101 
shrub plantings, 9,11,18,19, 
21,24,70,73,81 

82.85.91.99 

tree plantings, 18,19 

21.24.83.100 
Handicapped recreation 

facilities, 3 

High density recreation areas, 
20,22,87 

Historic tour route, 14,77, 
Hunting, 4,6,8,9,16,52,86, 

94,101 


I 

Income (see socioeconomics) 
Indirect economic effects, 67, 
68,87,95,103 
Inholdings, 1,18,19,26, 

31,84 

Interpretive facilities, 4,6, 
14,27,67,78,94 
nature trail, 14,20 
visitor contact station, 8,14, 
78 

exhibits, 14,78 


L 

Land purchases, 11 
Lewis and Clark Trail, 22 
Livestock grazing (see grazing) 
Livestock reductions, 10,12, 
17,18,20,21,24,70,71,74,78, 

83,84,86,87,89,100,101 
Livestock-wildlife interrelation- 
ships, 12,20,65,66,71,75,76 
82,90,92,98 

Longterm impacts, 61,63 
Low density recreation areas, 
20,22,87,94 

M 

Management responsibilities, 1 
Memorandum of Agreement, 33 
Mission fCMR) , 4 
Missouri River, 8,13,21,22,31, 
34,35,38,64,73,77,83 
Mitigating Measures, 8,16,20,22,25 
Mollisols (see soils) 

N 

National natural landmarks, 77 
National policy, 9 
National Register of Historic 
Places, 16,67,77 
Nature trail (see interpretive 
facilities) 

Nest structures, 7,21 
Noneconomic effects, 68, 
79,87,95,103 
Non-wildlife-oriented 
recreation, 6,67 

0 

Objective (National Wild- 
life Refuge System) , 33 

P 

Parent material, 37 
Perimeter shoreline scenic 
road, 22,93 
Piping, 35 

Ponderosa pine-juniper , 
viii,5,39, 74 


237 


Ponds 

brood, 7,18,21,45,63, 

83,90,99 
stock, 39 

Population (human), 27, 

57,60 

Predator control (see 

animal damage control) 
Prescribed burns (see 
fire management) 

Prescription grazing (see 
grazing) 

Primitive camp sites, 22, 

93 

Private cabins, 

8,14,18,20,26,27, 

52.66.87 

Public law, 2,32,57 
R 

Range condition, 12,21, 
24,41,62,65,67,71,74 
85,89,90,91 
Range deterioration, 

62.64,65,67,82,85,89, 

92,98 

Range developments, 

8,9,13,16,20,22,25,66, 

85.92.101 
boundary fences, 

10,13,18,20,25,71,81, 

86,92,98 

interior fences, 13,20, 

71.86.92.97 

water development projects, 
9,10,13,20,71,77,78, 

92.97 

Range objectives, 5,66,75,85,91 
94,99' 

Range survey, 41,65 
Recreation activities, 17,20, 

27.33.52.55.61.77.86.87 
Recreation areas, 8,11,13,16, 

17,20,22,23,25,26,27,37,50, 
66,67,77,78,86,87,100 
Recreation demand, 16,55,86,87 
Recreation objectives, 4,6,67,77 

86.94.101 ' 

Refuge Administration Act, 1 
Refuge Revenue Shading Act of 
1978, 57 


Research natural areas, 14 
Residual cover, 39,63,71,81 

82,84,90,92,98 

Rest-rotation grazing system 
(see grazing systems) 

Riparian zones, 5,16,19, 

21,22,41,64,73,90,91,99,100 
Riverbottom (riparian), 11,19,39, 
41,73,83 

Rorippa calycina , 50 

Sail/powerboat tour route, 14,78 
Scenic tour route, 14,27 
Scoping process, 1 
Seaplane landings (see aircraft 
landing) 

Seasonal grazing (see grazing) 
Seasons of use, 9,10,42,66,76,92 
Section 7 evaluations, 3 
Security cover, 19,21,39,64,65 
Short-term impacts, 61,71 
Sport fishing access, 16 
Slippery Ann area, 14,78 
Socioeconomics, 27,55,57,78,87, 

94,101 

benefits, 26,57,68 
costs, 26,55 

employment, 27,29,55-60,68, 
79,87,95,103 
income, 27,29,55-60,68, 
79,87,95,103 
Soils 

limitations & 
capability, 12,36 
(orders) : 

Aridisols, 36 
Entisols, 36 
Mollisols, 36 
Vertisols, 36 
Soil erosion, 13,20,37,62 

70,81,89,97 

Stock ponds (see range 
developments & ponds) 

Surveys 

aerial, 7 
ground , 7 

habitat analysis pro- 
cedures, 10 

range (methodology) , 41 


238 


T 

Taylor Grazing Act, 1 
Threatened species, 4, 

33,50 

Trails 

back-country, 14,20, 
22,78,87,93,94 
canoe, 14 

nature, 14,20,78,87 
Trapping, 9,52 
Turn-in dates, 12,13,76 

U 

UL Bend National Wildlife Refuge, 
21,50,83,85,90,91 
Unauthorized use, 52,61 
Unique species, 7,10, 

18,21,44,77 

Upper Missouri National Wild 
& Scenic River, 4,8, 
14,33,50,52 

V 

Vegetative types, 3,39 
Vertisols (see soils) 

Visitor contact station (see 
interpretive facilities) 

W 

Water development projects 
(see range developments) 

Water resources, 36 
Wilderness areas, 3,4,20, 

50,81,85 

Wildfires 

(see fire management) 

Wildlife habitat, 17,20,39, 
61,63,91 

Wildlife habitat analysis, 3, 

24 

Wildlife habitat management 
plan, 10,11,13 

Wildlife indicator species, 3 
(see indicator wildlife 
species) 

Wildlife-livestock problems 
(see livestock-wildlife 
interrelationships) 


Wildlife objectives, 5,9,10, 

16,26,74,83,85,93,99,100 
Wildlife-oriented recreation 
(see wildlife-related 
recreation) 

Wildlife pastures, 8,14,42,50 
Wildlife-related recreation, 
4,6,27,41,52,67,77,78,94,101 
Wildlife species 
amphibians, 50 
black-footed ferret, 

3,5,7,10,18,21,24,50, 

65.71.77.90.98 
birds, 44,45 
buffalo, 18,82 

bald eagle, ix,5,7,10,50 
bighorn sheep, 5,7,10,18, 

21.24.31.44.63.71.90.98 
elk, 11,16,19,24,26,39, 

42, 44, 57,64,71,73,74, 91, 

92.98.100 
fishes, 45 

peregrine falcon, 5,7, 

10,18,21,24,50,71,77,86, 

90,94,98,101 

prairie dogs, 3,5,10,44,71, 
72,81 

pronghorns, 3,5,7, 
11,26,31,44,64 

71.72.73.76.82, 

96.98.100 
mule deer, 3,5,7, 

11,16,19,39,42, 

64,71,72,73,76, 

82,83,85,91,93, 

98.100 

reptiles, 50 

sage grouse, 7,11,16, 

45.64.76.82, 

85.92.98.100 
sharp-tailed grouse, 

3,5,7,16,31,39, 

45.63.64.71.73.82, 

83.85.90.93.98.100 
swift fox, 10,18,21, 

24.77.98 

waterfowl, 5,7,16,45, 

63.73.83.93.98 
white-tailed deer, 5, 

16,19,41,42,64,73, 

98 

Wildlife tour route, 8,14, 

50,78 


239 


Wildlife winter range, 72, 
76,99 


Y 

Yearlong grazing 
(see grazing) 


240 



X. PUBLIC COMMENTS AND FWS RESPONSES 






Advisory 
Council On 
Historic 
Preservation 


1522 K Street. NW Reply »o: Lake Plata South. Suite 610 

Washington. DC 20005 44 Union Boulevard 

Lakewood. CO 60228 


October 2, 1980 


Mr. Erwin W. Steucke 
Area Manager 

Fish and Wildlife Service 
Federal Building, Room 3085 
Billings, Montana 59101 

Dear Mr. Steucke: 

Thank you for your request of August 1980 for comments on the draft 
environmental statement (DES) for Charles M. Russell National Wildlife 
Refuge in Montana. Pursuant to Section 102(2) (C) of the National Environmental 
Policy Act of 1969 and the Council's regulations, "Protection of Historic 
and Cultural Properties" (36 CFR Part 800) , we have determined that your 
DES does not contain sufficient information concerning historic and 
cultural resources for review purposes. Please furnish the following data 
indicating compliance with Section 106 of the National Historic Preservation 
Act of 1966 (16 U.S.C. Sec. 470f, as amended, 90 Stat. 1320). 

The environmental statement must demonstrate that either of the following 
conditions exists: 

1. No properties included in^or that may be eligible for inclusion in^the 
National Register of Historic Places are located within the area of 
environmental impact, and the undertaking will not affect any such 
property. In making this determination, the Council requires: 

— evidence that you have consulted the latest edition of the National 
Register (Federal Register , March 18, 1980, and its monthly supplements); 

— evidence of an effort to ensure the identification of properties eligible 
for inclusion in the National Register, including evidence of contact with 
the State Historic Preservation Officer (SHP0), whose comments should be ! 

included in the final environmental statement. The SHP0 for Montana is Dr. 
Robert Archibald. 

2. Properties included in or that may be eligible for inclusion in the 
National Register are located within the area of environmental impact, and 


Page 2 

Mr. Erwin W. Steucke 

Charles M. Russell National Wildlife Refuge 
October 2, 1980 


the undertaking will or will not affect any such property. In cases where 
there will be an effect, the FES should contain evidence of compliance with 
Section 106 of the National Historic Preservation Act through the Council's 
regulations. On page 20 it is stated: "Private cabins presently situated 
on CMR at the Pines, Fort Peck, Rock Creek State Park and Hell Creek State 
Park would be removed as the leases terminate. The areas woui.d be 
rehabilitated into suitable wildlife habitat." Prior to the removal or 
destruction of these structures, the Fish and Wildlife Service should 
evaluate them for inclusion in the National Register. If they are found 
eligible then the Fish and Wildlife Service will be responsible for 
affording the Council an opportunity to comment on any undertaking it 
proposes that will affect them. I 

Should you have any questions, please call Ms. Betty J. Lefree at (303) 
234-4946, an FTS number. 



Louis S. Wall 
Chief, Western Division 
of Project Review 


Response to Advisory Council on Historic Preservation 


1. Because of the sensitive nature of these resources and their 
vulnerability to unauthorized collecting activities on this million- 
acre area, detailed information was intentionally omitted from the 
environmental statement. However, we have coordinated closely with 
the Montana State Historical Society, and they have been advised of 
the historic and cultural resources that are known to exist on the 
Refuge . 

It is stated that before any action is taken which may Impact 
cultural resources, individual site surveys will be completed. In 
further compliance, the Fish and Wildlife Service will be glad to 
afford the Advisory Council on Historic Preservation an opportunity 
to comment on any proposed action affecting these resources. Thus, 
neither the Proposed Action nor any of the other alternatives 
described in the DEIS would adversely affect historic or cultural 
resources. 

2. Should the alternative that is eventually selected for implementa- 
tion involve the removal or destruction of any structures situated 
on the refuge, these structures will be evaluated by the Fish and 
Wildlife Service for their possible inclusion in the National 
Register. 


2 October 1980 


Mr. Erwin W. Steucke, Area Manager 
U.S. Fish S Wildlife Service 
Federal Building, Room 3035 
316 North 26th Street 
Billings, Montana 59101 


Dear Mr. Steucke: 


The C.M. Russell NWR Advisory Committee has briefly reviewed the draft 
EIS on management of the refuge. We generally support the content and 
intentions of Alternative B (Proposed Action), but wish to register the 
following proposed changes and comments. 

Proposed Changes 

1) Page 10, under Habitat Management, line 11; after "...agency's 
objectives" add "after consultation and agreement between the 
FWS, BLM, and concerned permittees." 

2) Page 13, under Range Developments , paragraph 3, line 2 1 after 
...."or recreation programs..." change period to a comma and 
add "except that stock-watering facilities will be developed 
If boundary or other fencing leaves any grazing allotments on 
the Refuge or adjacent land without water." 

Comments 

1) Page II, Paragraph 3; the committee was divided on If and how 
cooperative farming should be phased out. Each member will 
comment on this as an Individual. 

2) The committee agreed that phasing out cooperative farming on 
one hand to maintain "naturalness" and ripping 10,000 acres 
to Improve wildlife habitat was Inconsistent. Also, ripping 
should not occur on any sage grouse wintering sites. 

3) One member pointed out mistakes in the numbers presented for 
presently-licensed AUM's. Individual permittees will point 
out mistakes, and every effort should be made to rectify these. 

A draft of this letter was reviewed and approved by the committee. 

Sincerely, 

10 ( — 

Bart W. 0'Gara 
Secretary 


2 


241 


Responses to C.M. Russell NWR Advisory Committee 


1. The EIS has been appropriately modified. 

2. The EIS has been appropriately modified. 

3. After reviewing public comment and reexamining pertinent research, 
the FWS has concluded that soil ripping is not a viable manipula- 
tive technique for habitat management on CMR. All references to 
ripping have been deleted from the proposed action. 

4. Every effort has been made to eliminate errors. 


UNITED STATES DEPARTMENT OF AGRICULTURE 

SOIL conservation SERVICE P.0. Box 1078, Lewistown, Montana 59457 


December 8, 1980 


Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 


Comment on draft environmental Impact statement on Charles M. Russell 
National Wildlife Refuge. 


The CMR EIS Is approached as a refuge entity without sufficient con- 
sideration of the Influences of the adjacent area. For instance 
several wildlife species habitat parlmeters include critical habitat 
outside the refuge boundaries. 

i 

With the long Irregular narrow land pattern of the refuge plus the 
fact the land Is split by the Fort Peck Reservoir, it would be diffi- 
cult In managing for wildlife maximums without Increasing wildlife 
pressures on the private sector. 

There should be another alternative Including Intensive management 
of the livestock use as a tool In Improving the overall range con- 
dition and especially on excellent condition range. 

2 

The EIS indicates that light stocking Is significantly better than 
moderate stocking of livestock for wildlife. This will vary as to 
range condition which Is not discussed sufficiently In the EIS. 

3 

There Is an Indication of conflicting effects to fencing. Why should 
cross fences If properly designed have detrimental effects on some 
wildlife, yet If the refuge boundary is fenced there would be no sig- 
nificant detrimental Impacts to wildlife expected. 

4 



Sam L. Short 

Area Range Conservationist 

6 


Response to the USDA Soil Conservation Service 


1. The concept of ecosystems was recognized in the development of 
management plans, and adjacent landowners have been involved in the 
planning process. 

2. The Proposed Action and Intensive Wildlife Management alternatives 
are in fact prescription grazing alternatives. Each allotment will 
be evaluated, and a grazing system will be developed based on an 
allotment's individual characteristics. 

3. Based on current habitat (not range) conditions, light stocking is 
needed to promote increased shrub growth and other habitat quali- 
ties now lacking. Once these conditions are achieved, moderate 
stocking may be more desirable in some areas. 

4. The FWS does not expect there will be significant differences in 
impacts between boundary fencing and cross fencing pastures. 


DEPARTMENT OF THE AIR FORCE 
AIR FORCE REGIONAL CIVIL ENGINEER CENTRAL REGION (AFESC) 
1114 COMMERCE STREET 
DALLAS TEXAS 75242 

28 November 1980 


Mr. Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

Dear Mr. Steucke 

Thank you for the opportunity to review the draft environmental impact 
statement on management of the Charles M. Russell National Wildlife Refuge. 

We fully support the establishment and management of wilderness areas; 
however, you should be cognizant of the fact that Air Force training re- 
quirements have the potential for creating disturbances to ground activities. 

The Air Force currently operates the Hays Military Operating Area (MOA) 
which is located primarily west of the reservoir; however, a portion of the 
MOA overlaps the reservoir proper at altitudes from 8,000 to 18,000 feet 
mean sea level. Although a floor of 8,000 feet does not impact animal and 
most bird habitation, this altitude does not permit realistic low altitude 
maneuvering. The Air Force is proposing to reduce the lower limit of this 
MOA to 3,000 feet above ground level (AGL). In addition, there is a request 
to extend a route from instrument route (IR) 404 to the Hays MOA to enable 
aircraft to enter the MOA from the east. IR 404 currently traverses the 
eastern edge of the management area as low as 400 feet AGL. Any route 
adjustment to accommodate this request will more than likely penetrate 
the reservoir area. These Air Force activities may have an impact on the 
proposal to reintroduce endangered or unique species into the management 1 

area. In selecting suitable reintroduction sites we ask that you recog- 
nize our need to conduct realistic training and make provisions accordingly. 

While conflicts between Air Force flying areas/routes and the proposed 
management area are few, route and airspace requirements of the military 
are subject to change and do change frequently. Mission requirements, 
fuel costs, and environmental constraints all act on the decision to 
locate a military training activity. Because of general aviation and 
population pressures, the Air Force has relegated low altitude high speed 
flight to those areas least accessible and sparsely inhabited. 

It is essential that management of the Charles M. Russell National 
Wildlife Refuge area be carried out so as to not restrict use of low 
altitude airspace by the Air Force. 

Sincerely 

JJU 

EL0 MUSSETT0, Colonel, USAF 
Regional Civil Engineer 


Cy to: SAC/DEV 
TAC/DEV 
AF/LEEV 
AFESC/DEV 
341 CSG/DEE V 
AFREP/FAA CR/GLR/RMR 



242 


Response to the Department of the Air Force 


1. The FWS recognizes the potential for creating ground disturbance 

from overflights in the Hays Military Operating Area. Ongoing and 
future management actions will take these factors into considera- 
tion. Any future conflicts will be addressed by the FWS and Air 
Force towards reaching mutually satisfactory arrangements. 



DEPARTMENT OF THE ARMY 
6014 U S POST OFFICE AND COURTHOUSE 


MROPD-A 


25 November 1980 


Mr. Erwin W. Steucke 
Area Manager 

U.S. Fish and Wildlife Service 
Room 3035, Federal Building 
316 North 26th Avenue 
Billings, MT 59101 


Dear Mr. Steucke: 

This office has reviewed the Draft Environmental Impact Statement (DEIS) 
on the management of the Charles M. Russell National Wildlife Refuge 
(CMR) in Montana. We are inclosing our comments for your consideration 
in development of the Final Environmental Impact Statement. 

Thank you for giving us the opportunity to provide these comments, which 
we hope will be of assistance to you. 

Sincerely, 


V s ' ARVID L. THOMSEN 

Acting Chief, Planning Division 


1 Incl 
As stated 


General Comments: 


Page x, paragraph 1, No Action Alternative. The last sentence states that 




"Recreational developments would remain essentially unchanged." This state- 


We agree that Alternative B (Proposed Action) is the most desirable alterna- 


ment may conflict with planned recreation concepts and developments presently 


tive and also acknowledge that there will be some social and economic obsta- 


under consideration in the Corps of Engineers Master Plan for the Fort Peck 


cles to overcome in implementing this alternative. The other alternatives 


Lake Project. It is recommended that this sentence be rewritten as follows: 

2 

may not be implementable under existing Fish and Wildlife Service laws and 




policies. 


"Any changes in the status of recreational development would be 




accomplished in accordance with the Memorandum of Agreement of 


We recognize that several constraints alter normal refuge management, however. 


July 1979." 


we highly recommend the refuge be managed as a National Wildlife Refuge, to 



the greatest extent possible. 


Page x, paragraph 5, Intensive Wildlife Management Alternative. The last 




sentence states that "...COE-FWS legislative conflicts would have to be 


We recognize that good winter habitat is a critical element in the survival 


resolved in favor of FWS." These conflicts have been resolved by the Memo- 

3 

of wildlife in the Missouri River breaks country of eastern Montana and encour- 


randum of Agreement signed in July 1979 by the two agencies and thus the 


age you to consider a more extensive shrub and tree planting program than is 


wording quoted above should be deleted from the sentence. 


recommended in Alternative B. We recommend plantings specifically in the 



valley draws, canyons and ponds which will support plant growth. Also, we 


Page xi, paragraph 4, Intensive Wildlife Management Alternative. The second 


recommend these areas be fenced to preclude damage by cattle. Our experience 


sentence states that "Private cabins would be eliminated and the areas re- 


indicates that habitat damage by cattle is a far greater detriment to the 


turned to wildlife habitat." This statement is not consistent with the 

4 

naturalness of an area than is the fencing of critical habitat areas. This 


Memorandum of Agreement signed by the Corps and FWS in July 1979, nor is the 


type of fencing insures the permanency of the habitat during winter and 


statement consistent with past interagency discussions. It is recommended 


drought periods. 


that this sentence be deleted from the paragraph. 


We also recommend that cooperative farming be implemented in areas where the 


Page 1, last sentence. The last sentence should be rewritten as follows: 


visual naturalness is not interrupted. This will diversify the habitat, food 



5 

source and therefore the wildlife. 


"The COE held public meetings also at Glasgow, Lewistown, Glendive 




and Jordan In June 1979." 


The grazing of livestock should not be eliminated, but remain primarily as a 



habitat management tool. 


Pages 4, 5, and 6. We agree with the CMR goals, wildlife objectives and 



range objectives. 

Specific Comments: 





Page 5, Wildlife Objectives. On page x it states that the "...swift fox 

6 

Page i, paragraph 2, Foreword. Further discussion in this paragraph may be 



would be reintroduced as they become available." There is no mention of 

warranted to clarify how Public Law 94-223 solved part of the management 



this species under wildlife objectives. 


problem on CMR. The first sentence states that... "the conflicting legisla- 




tion and mandates between the Corps of Engineers and the Fish and Wildlife 



Page 9, paragraph 3, General. The first two sentences state that "Clarifi- 


Service remain.” This wording should be deleted from the sentence since all 



cation of conflicting legislation and management responsibilities between 


jurisdictional questions between the two agencies have been resolved in a 



COE and FWS would be sought. A cooperative effort with COE would be launched 

_ 

Memorandum of Agreement signed in July 1979. It is further recommended that 



to determine ownership of all lands within the CMR boundary." These two 


this paragraph be rewritten as follows: 



sentences, along with the rest of the paragraph should be deleted since the 





above issues are presently being coordinated according to Memorandum of Agree- 


"Passage of Public Law 94-223 in 1976 has solved part of this 



ment signed in July 1979. 


management problem. Al$o, a Memorandum of Agreement was signed 




by the Corps of Engineers and the U.S. Fish and Wildlife Service 



Page 13, last paragraph. This paragraph states that "FWS would work with the 


in July 1979. The agreement was signed to insure that both agencies 



COE in recommending operation of the Fort Peck Dam and Reservoir in a manner 


coordinate all future planning activities on the Charles M. Russell 



which would tend to limit water level fluctuations to enhance recreation and 


National Wildlife Refuge." 



fisheries opportunities..." The Corps of Engineers acknowledges the lmpor— 

8 



tance of water level fluctuations in fisheries management and recreation. 




The Corps will work with the FWS and coordinate the missions of FLOOD CONTROL, 




NAVIGATION, IRRIGATION AND POWER GENERATION, with fisheries management and 


1 


recreation when possible. 

2 



243 


Page 15, Figure 1. The following recreation areas should be shown on the I 

map: Reynolds Hill Road Recreation Area (future); the Pines Recreation 1 9 

Area; and the Flat Lake Recreation Area. 


Page 16, Mitigating Measures. Suggest constraints be softened to allow for 
mitigating measures. These would include fencing, construction of stock 
ponds and other management facilities, etc. where the visual naturalness 
would not be impaired. This would retain a natural and/or rustic setting 
on the refuge. 


10 


Page 17, last sentence. This sentence states that "If recreation activities 
result in significant conflicts with wildlife, actions would be taken as 
necessary to solve the problem." This type of an issue will be dealt with 
under the terms of the Memorandum of Agreement signed by the two agencies 
in July 1979, thus the sentence is Inappropriate in this document. 


Page 18, paragraph 1. This paragraph contains two specific statements 
recommending the removal of private cabins. These statements are not con- 
sistent with the Memorandum of Agreement signed by the Corps and FWS in 
July 1979, nor are they consistent with past Interagency discussions. It 
is recommended that these statements be deleted from the paragraph. The 
third sentence states that "The legislative conflicts between COE and FWS 
would have to be resolved...". This sentence Implies that additional legis- 
lation would be proposed to clarify past jurisdictional issues. Since all 
jurisdictional Issues have been resolved by the Corps of Engineers and the 
U.S. Fi6h and Wildlife Service in the Memorandum of Agreement signed in 
July 1979, it is recommended that the entire sentence be deleted from the 
paragraph. 


Page 26, paragraph 3, last sentence. This sentence states that "Removal of 
private cabins would require that the FWS-COE legislative conflicts be 
resolved in favor of FWS." This sentence is not consistent with the Memo- 
randum of Agreement signed by the Corps and FWS in July 1979, nor is the 
sentence consistent with past Interagency discussions. It is recommended 
that this sentence be deleted from the paragraph. 

Page 54, Figure 8. The following existing recreation areas should be 
shown on the map: The Pines Recreation Area and the Flat Lake Recreation 14 

Area . | 


13 


Summary Comments : 

Regardless of the management alternative finally selected for implementa- 
tion on CMR, the Corps of Engineers will continue to coordinate with the 
FWS to Insure that all Federal lar\ds within the (MR boundary are managed 
in the public's best interest. 


3 


Response to the U.S. Army Corps of Engineers 


1. The foreword has been rewritten* 

2. FWS agrees; the text has been amended. 

3. The text has been amended. 


4. This action is not proposed but is an alternative. Management 
conflicts of this type would be cooperatively resolved within the 
terms of the Memorandum of Agreement between the Corps of Engineers 
and the FWS. 

5. The text ha6 been amended. 

6. The text has been amended. 

7. The text has been amended. 

8. The text has been amended. 

9. The map has been revised. 

10. The decision to manage in a "generally natural setting" is in 
accordance with FWS legislative mandates and policies. In exami- 
nation of HEP values compiled on allotments, it has been concluded 
that additional water development would be detrimental to most 
wildlife species by distributing livestock into areas now needed 
and used almost exclusively by wildlife. Situations will, however, 
be evaluated on a case-by-case basis. 


11 . 


13. 


The text has been amended . 
The text has been amended. 
The text has been amended. 
The map has been revised. 


/js£\ 


UNITED STATES DEPARTMENT OF COMMERCE 
The Assistant Secretary for Policy 

Washington. D C 20230 


NOV 1 1 198° 


Mr. Erwin W. Steucke, Area Manager 

Fish and Wildlife Service 

U.S. Department of the Interior 

Federal Building, Room 3035 

316 North 26th Street 

Billings, Montana 59101 

Dear Mr. Steucke: 

This is in reference to your draft environmental impact statement 
entitled, "Management of Charles M. Russell National Wildlife Refuge, 
Montana." The enclosed comment from the National Oceanic and Atmospheric 
Administration (NOAA) is forwarded for your consideration. 

Thank you for giving us an opportunity to provide this comment, which we 
hope will be of assistance to you. We would appreciate receiving six 
copies of the final statement. 




Robert T. Miki 

Deputy Assistant Secretary for 
Regulatory Policy (Acting) 


Enclosure Memo from 


Mr. Kenneth Hadeen 
Environmental Data and 

Information Service, NOAA 


UNITEO STATES DEPARTMENT OF COMMERCE 
National Oceanic and Atmospheric Administration 

ENVIRONMENTAL DATA ANO INFORMATION SERVICE 
Washington. 0 C 20235 

Center for Environmental Assessment Services 
October 2, 1980 D242:MR 


TO: PP/EC - Joyce Wood 

FROM: OA/D2xl4 l Kenneth Hadeen £, 0 - 

SUBJECT: DEIS 8009.20 - Management of Charles M. Russell National Wildlife 

Refuge — Montana 


General Comments : None. 



Specific Comaents (See page 33 under Climate Section) 

The DEIS states that winters are bitterly cold (-34°F to -50°F) and summers 
are hot (100°F+). The DEIS would be more precise if it stated that winters are 
moderately cold (average January minimums are near 0°F) . Occasionally, bitterly 
cold periods with temperatures of -20°F or lower are experienced, and the lowest 
on record is -58°F. Summers are what most people would consider pleasant, with 
low humidity and afternoon readings in the middle 80' s and morning minimums in 
the middle 50' s. Occasionally, periods of 100°F temperatures are experienced, 
with an extreme of 112°F being the highest on record. 

(RF: D242 , R. Leffler) 



TOTH ANNIVERSARY 1970-1980 
National Oceanic and Atmospheric / 

A young agency with a histone 
tradition of service to the Nation 


244 


Response to National Oceanic and Atmospheric Administration 


1. The text has been amended. 


‘ ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

\ REGION VIII 

1860 LINCOLN STREET 
DENVER. COLORADO 80295 

DEC 9 1980 

Ref: 8M0 

Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
Billings, Montana 59101 

Dear Mr. Steucke: 

Thank you for the opportunity to review your agency's draft environmental 
impact statement (EIS) for Management of Charles M. Russell National Wildlife 
Refuge. We appreciate the complexity of the management problems facing you 
and support your efforts to improve the protection of the natural environment 
of this beautiful area. 


\ 

\ 


EPA comments are as follows: 


1. We support your proposed alternative because it best meets the 
objectives for which the Refuge was established. This alternative should also 
better protect the area's soils and related water quality values. 


2. We would suggest that you examine the possibility for more gradual 
reductions in cattle use of the area than is proposed under the selected 
alternative. A gradual approach could lessen the economic impact on the 
ranchers involved. 


3. Is there a possibility that improved range conditions and consequent 
better forage could offset, to some degree, a lesser number of AUM's as 
proposed under your preferred alternative? 

A. Though it appears to be an improvement over the present situation we 
do not believe the multiple use alternative best meets the objectives of the 
Refuge. We would suggest that the multiple use alternative include an 
analysis of the impacts of a shoreline scenic drive and possible trail. 

According to EPA's rating system for draft impact statements, this EIS is 
rated L0-1 (lack of objections - sufficient information). If you have any 
questions, please contact Mr. Gene Taylor in our Helena, Montana Office at 
(406) AA9-5A86. 


Sincerely yours 






Response to Environmental Protection Agency 


1. The FWS agrees, and this will be considered when planning imple- 
mentation of the management plan. 

2. If evaluation in the future shows that wildlife objectives can be 
met with more livestock AUMs than provided for in the Proposed 
Action, consideration will be given to increasing livestock AUMs. 

3. The Multiple Use alternative will not achieve the wildlife goals 
and objectives. This alternative does include a shoreline scenic 
drive and cross-country trail along a portion of the CMR Refuge, 
the impacts of which have been addressed on page 9A of the FEIS. 



DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 
WASHINGTON, D.C. 20410 


Mr. Don W. Minnlch 

Regional Director 

U.S. Department of the Interior 

Fish and Wildlife Service 

P. 0. Box 25486 

Denver Regional Center 

Denver, Colorado 80225 

Dear Mr. Minnich: 

Subject: Draft Environmental Impact Statement 

on the Management of the Charles M. Russell 
National Wildlife Refuge in Montana 


Thank you for providing us the opportunity to review the above draft Environ- 
mental Impact Statement (EIS). In accordance with 24 CFR Part 50 Protection 
and Enhancement of Environmental Quality, Department of Housing and Urban 
Development procedures, particularly Section 50.61 of our Regulations, we are 
forwarding the EIS to the responsible HUD Regional Environmental Officer. He 
will review and comment as appropriate, directly to you by your due date. 

To assure prompt review of all non-HUD EIS's, you should send copies of all 
future EIS's as follows: 

1. All EIS's on legislative proposals, regulations, or policy documents of 
national significance should be sent to Mr. Richard H. Broun, Director, 
Office of Environmental Quality, HUD, Washington, D. C. 20410; and 

2. All other EIS's should be forwarded to the appropriate HUD Regional Office 
for conment. We have enclosed a list of our Regional Environmental 
Officers and their addresses. 

If you have any questions In this regard, please feel free to contact me at 
(202) 755-6300. 


Sincerely, 


Richard H. Broun 
Director 

Office of Environmental Quality 


Enclosure 


245 



DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT 
REGIONAL/AREA OFFICE 
EXECUTIVE TOWER - 1405 CURTIS STREET 
OENVER, COLORADO 80202 


REGION VIII 


October 22, 1980 




8SOQ 


Mr. Erwin W. Stencke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

Dear Mr. Stencke: 


Thank you for the opportunity to review and comment on the draft 
Environmental Impact Statement for Management of Charles M. Russell 
National Wildlife Refuge in Montana. 

Your draft has been reviewed with specific consideration for the areas 
of responsibility assigned to the Department of Housing and Urban 
Development. The review considered the proposals' compatibility 
with local and regional comprehensive planning and impacts on 
urbanized areas. Within these parameters this document is adequate 
for our purposes. 


If you have any questions regarding these comments, please contact 
Mr. Carroll F. Goodwin, Area Environmental Officer, at FTS 327-3102 
in Denver, Colorado. 

Sincerely, 




United States Department of the Intenor 

BUREAU OF LAND MANAGEMENT 
222 North 32nd Street 
P.0. Box 30157 
Billings, Montana 59107 


Memorandum 


OEC 5 1980 


IN REPLY REFER TO: 

1791 (931) (962) 


To: Regional Director, Fish and Wildlife Service, P.0. Box 25486, 

Denver Federal Center, Denver, Colorado 80225 


From: State Director 


Subject: Comments on Proposed Management of CMR National Wildlife Refuge, 

Montana 


We have reviewed the Draft EIS for Management of CMR National Wildlife 
Refuge and have the following observations. 


We in the Bureau of Land Management (BLM) are keenly interested in the 
wildlife resources of the region surrounding the Wildlife Refuge. We 
recognize that most wildlife species are as dependent on adjoining 
habitat on BLM, state and private lands as they are on lands inside the 
Refuge boundary. Livestock grazing is also a critically important and 
historic use of the lands inside and adjacent to the Refuge. 

Our basic recommendation to Fish and Wildlife Service will be to select a 
plan alternative that will provide for cooperative planning for multiple 
use resource management; a plan that provides the flexibility to work 
with all affected agencies and private landowners to meet the best multiple 
use combinations for the region. We believe that this would strengthen 
our respective wildlife habitat management programs and would help to 
maintain the historic and economic uses of all lands in the area as well. 

We are aware that the primary role of Fish and Wildlife Service in managing 
the CMR is protection and enhancement of wildlife habitat and related 
resources. BLM is responsible for sound multiple use management of a 
variety of resources, not the least of which is wildlife habitat. Despite 
the fact that we have somewhat different management objectives, we believe 
that we must work together with mutually beneficial programs to meet our 
respective goals. Because of the intermingled land ownership pattern 
inside and outside the Refuge, it is also imperative that we closely coordinate 
our activities with the state and private landowners if we are to success- 
fully implement these programs. 

The livestock permittees on and near the CMR Refuge have, for the most part, 
contributed extensively to the success of current wildlife management 
programs in the area. While there are instances of overuse and abuse of 
the land, most operators have taken a real interest in the wildlife res^&roBs, 
Notable is the cooperation and assistance provided in introducing and' 
establishing the elk and bighorn sheep populations in the 1950 's an<f 4-96^' s, 
and turkey feeding during the hard winter of 1968. Lands owned andf/btoiltreoile'd 
by the permittees also contribute significantly to habitat for a variety 
of the wildlife species using the refuge. 


2 

From an ecological and practical standpoint it is not feasible to separate 
the CMR Refuge from the rest of the region. Even if it were practical to 
fence the Refuge boundary to control livestock, there are too many over- 
lapping uses requiring coordinated consideration and management. We are 
convinced that a multiple use and cooperative approach must be used to 
obtain the desired results of first rate wildlife habitat on the CMR Refuge 
and surrounding areas. We fully intend to work with your agency and other 
associated landowners and agencies toward that end. 


Director (222) 
DM, Lewistown 
DM, Miles City 



United States Department of the Interior 

GEOLOGICAL SURVEY 
RESTON, VA 22092 


m 4 l3a9 

Memorandum 


To: Area Manager, Fish and Wildlife Service 

Billings, Montana 

Through ^Assistant Secretary— Energy and Minerals 
From: Director, Geological Survey 


7 1980 


Subject: Review of draft environmental statement for management of 

Charles M. Russell National Wildlife Refuge, Montana 

We have reviewed the draft statement as requested in the Regional 
Director's letter of August, 1980. 

Measures such as sediment traps and stream buffer strips should be I 

considered for use in reducing sediment discharge to streams, especially M 
from any currently disturbed land areas (p. 38). I 




r 


H. William Menard 



One Hundred Years uf Earth Science in the Public Service 


246 


Response to U.S. Geological Survey 


1. While sediment traps and stream buffer strips are methods of re- 
ducing sediment discharge, road modification to avoid areas of 
excessive erosion due to rutting is also a workable method. The 
FWS will evaluate each situation and utilize the best one for each 
area. 



IN REPLY REFER TO; 

1202-04 


United States Department of the Interior 
HERITAGE CONSERVATION AND RECREATION SERVICE 
MID-CONTINENT REGION 
POST OFFICE BOX 25387 
DENVER FEDERAL CENTER 
DENVER. COLORADO 80225 


NOV 1 3 1980 


MEMORANDUM 

To: Area Manager, Fish and Wildlife Service, Billings, 

Montana 

From: Assistant Regional Director, Land Use Coordination 

Subject: Draft Environmental Statement for Management of Charles 

M. Russell National Wildlife Refuge, Montana (DES 80-55) 


Inventory and protection of cultural resources is a direct responsi- 
bility of the federal agency administering land. Early survey and 
identification of the cultural resources in the wildlife refuge will 
allow cost-effective planning and management of the resources. There- 
fore, we encourage the completion of surveys as soon as possible. 

Additionally, discussion of impacts to cultural resources in the 
wildlife refuge is generally not adequate. Actions such as grazing, 
burning and an increased number of visitors can adversely impact 
these resources. These impacts, along with measures designed to 
minimize harm to cultural resources should receive consideration in 
the final statement. 



Robert J. Arkins 


Response to Heritage Conservation and Recreation Service 


1. The FWS will comply with all pertinent legislation concerning the 
Identification and protection of cultural resources. No signifi- 
cant impacts on cultural resources are anticipated by the proposed 
action. Also, please refer to page 3, paragraph 2, and Recreation 
Objective number 1 on page 6 in the text. In addition, impacts to 
cultural resources are discussed throughout the text in the 
Consequences Section. 



247 


Response to National Park Service, Midwest Region 


1. Recreation and interpretation related to cultural resources were 
evaluated for inclusion in various alternatives based on their 
compatibility with wildlife objectives. Many of the ones included 
in the alternatives relate to the Lewis and Clark Expedition. 



IN REPLY REFER TO: 


United States Department of the Interior 

NATIONAL PARK SERVICE 
ROCKY MOUNTAIN REGIONAL OFFICE 
655 Purfel Street 
P.O. Box 25287 
Denver. Colorado H0225 


L7619 (RMR)PC 

OCT 3 1980 


Memorandum 

To: Area Manager, Charles M. Russell National Wildlife Refuge, 

United States Fish and Wildlife Service, Billings, Montana 

From: Associate Regional Director, Planning and Resource Preservation, 

Rocky Mountain Region 

Subject: Draft Environmental Impact Statement (DEIS), Management of 

Charles M. Russell National Wildlife Refuge 


We have reviewed the subject DEIS. No units of the National Park System 
will be directly affected by the proposed management program. 

However, we believe the first paragraph under Recreation and Cultural 
Resources for Alternative D on page 22 is somewhat inaccurate. The 
amendment to the National Trails System Act by the National Park and 
Recreation Act of 1979 only identified and established a Lewis and Clark 
National Historic Trail. It did not specify a Lewis and Clark highway 
route per se, but rather leaves to a comprehensive plan to determine pre- 
cisely where the trail route will go. We suggest the following be 
substituted to make the paragraph more accurate: 

"All recreation proposals ... would be interpreted. The trail would 
be nominated as a component of the Lewis and Clark National Historic 
Trail upon completion of a comprehensive plan for the national 
historic trail by the National Park Service." 

The Regional Director of the National Park Service Midwest Regional Office, 
1709 Jackson Street, Omaha, Nebraska 68102 is responsible for preparing the 
above-mentioned comprehensive plan. We suggest you consult with that 
Regional Director as to how your proposed trail would fit in with the 
comprehensive plan. 



Richard A. Strait 



Response to National Park Service, Rocky Mountain Region 


1. The text has been amended. The FWS will coordinate the Lewis and 
Clark National Historic Trail with all agencies involved. 


DEPARTMENT OF TRANSPORTATION 
UNITED STATES COAST GUARD 1 

:"l5o8“«4?-7523 

’16476 

DPL80-913 


Mr. Don W. Minnich 
Regional Director 

United States Department of the Interior 

Fish and Wildlife Servie 

Post Office Box 25486 

Denver Federal Center 

Denver, CO 80225 

Dear Mr. Minnich: 

We have reviewed your draft Environmental Impact Statement for 
Management of the Charles M. Russell National Wildlife Refuge in 
Montana, dated August 1980. Our review and comments are in 
keeping with parts 1508.15, 1508.26 and 1503.2 of the Council on 
Environmental Quality Regulations for implementing the National 
Environmental Policy Act (40 CFR 1500-1508). 

Pursuant to the Council on Environmental Quality Regulations we 
have no comment on your environmental statement. Thank you for 
providing us with the opportunity to review this document. 



Chief of Staff 

13th Coast Guard District 


Copy: Commandant (G-WS-1), U. S. Coast Guard 




248 



Cooperative Extension Service 

MONTANA STATE UNIVERSITY. U S DEPARTMENT OF AGRICULTURE. AND MONTANA COUNTIES COOPERATING 

MONTANA STATE UNIVERSITY 
BOZEMAN. MONTANA 59717 


November 28, 1980 


Area Manager 

U.S. Fish and Wildlife Service 

Room 3035 

Federal Building 

316 North 26th Avenue 

Billings, MT 59101 


Dear Area Manager, 

I have been reviewing the dEIS for management of the Charles M. Russell 
National Wildlife Refuse. In particular, I have been studying the socio- 
economic analysis. I am pleased to see that the analysis include total effects, 
regional effects, - in terms of both dollars and labor and distribution of 
impact among lessees. However, there are some specific questions that I believe 
should be reviewed before deriving the final EIS. Some of my questions are 1 

tentative because I find it very difficult to tell whether the economic analysis 
is complete. I am concerned that the very large investment and 0"M cost of some 
of the alternatives be included. In particular, I cannot tell whether the cost 
of acquiring in-holdings, building and maintaining fences and other developments 
are included. I will mention this again. 


Value of AUM's and Recreation : I fully appreciate the difficulty of estimating 

these values. It appears the analyst has been conservative on values of both 
AUM's and Recreation. This EIS should not bear the burden of trying to answer 
this knotty problem, but it is interesting to me to calculate that the difference 
between CMR and Market Lease Rates for the 60,108 AUM's on the CMR might itself 
amount to about $400,000 per year. Is this all or in part a subsidy to present 
lessees? Likewise, the growth factors for recreational activities appear low 
compared to the data presented in Table 13 A, page 187. 


In-Holdings : Is the reduced economic activity associated with acquiring in- | 

holdings that are range headquarters included? They should be included in the 13 

cost and in the regional analysis. 


Regional Effect : What regional multiplers were used for agriculture and re- |j 

creation. Are they different? I would expect more regional leakage from |4 

recreation but that may not be the case. 


Indirect Effects : In my view, indirect effects are those that extend beyong 

the project itself. On page 106, indirect effects are defined as effects re- 
moved from the project in time and geography. Were this true, we would have a 
hard time including direct effects, removed in time, in our present value estimates. 
In so far as I can tell, indirect effects are correctly handled and calculated, 
but incorrectly defined. 


5 


Appendix 11 , last line : It appears the decimals should be commas (3.452 should 




Area Manager, Fish & Wildlife Service 
page 2 


be 3,452 etc.) Further, per-capita income should not be totaled across 
the counties but omitted or averaged to avoid distortion. 

B-C analysis : The text (page 191) says costs are discounted to present 

value but the data in Table 13 C show equivalent costs for 1985 and 2000. 

This seems inconsistent. The net direct effects (bottom of Table 13 C) 
don't reveal much because costs are not included. Regardless of the dis- 
claimer on page 191, I would like to see the present net value of the alter- 
natives. For example, does 0&M include maintanence of the 400 miles of fence? 
The last paragraph on page 191 suggests that the source is current costs for 
0&M obtained from the Refuge. Are these costs and are they used to calculate 
0&M for fence, etc.? 

Present value : The explanation of present value on page 191 is hard to under- 

stand and I have not been able to reproduce the results. Even if they are 
correct, I would like to see the argument presented a different way, perhaps 
as streams of benefits arising from investment and 0&M. 

Grazing on the multiple use alternative : The summary indicates livestock 

would receive approximately one-half of the allocated forage but, on page 94, 
it is indicated that this alternative would result in a decrease of 8,012 
AUM's from a base of 60,108. The summary appears inconsistent with page 94 
and the corresponding Table in the appendixes. 

I hope that niy comments will be useful to you in reviewing the dEIS. 

Sincerely yours, 

it) >^YA&2_ 


Verne W. House 

Public Affairs Specialist 


Response to Montana Cooperative Extension Service 


1. The entire economic evaluation has been redone and the narrative 
revised to better explain the situation. The costs acquiring in- 
holdings, buildings, maintaining fences, and other developments are 
not addressed in the EIS. 

2. The AUM value to the rancher has been reestimated using the line 
programming approach, which takes into account the difference in 
grazing conditions and services provided. The new AUM value used 
is $12.87. The entire economic evaluation, narrative, and related 
appendices have been revised. 

3. See response 01 above. 

4. The agricultural gross output multiplier used in the revised econo- 
mic evaluation is 2.67, and that for tourism, 1.77. 

5. The section on page 206 has been revised. A better definition is 
found in the glossary on page 232. 

6. Appendix 11 has been corrected. 

7. Present values and calculations of items in discounted terms have 
been dropped. The dollars in the report are in current dollar 
terms. Since a benefit cost analysis is not being prepared, net 
present value in a part of the EIS is of little use. The entire 
economic situation has been reevaluated and revised in the text. 

8. The text has been amended. 



MONTANA HISTORICAL SOCIETY 

225 NORTH ROBERTS STREET • (406) 449- 4584 • HELENA. MONTANA 59601 


September 24, 1 980 


Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building Room 3085 
316 North 26th St. 

Bi llings, MT 59101 

Re: Draft Enf i ronmental Impact Statement 

Charles M. Russell National Wildlife 
Refuge 

Dear Mr. Steucke: 

Thank you for the opportunity to comment on Draft Environmental 
Impact Statement identified above. In general, we do not find its 
consideration of cultural resources to be adequate in the context of 
the 1966 National Historic Preservation Act, E. 0. 11593, or 36 CFR 800 
or appropriate for the basic ground rules of cultural resource preservation. 
Our specific findings and concerns are outlined below: 


a) Given the strength and rationale of the mandates for Federal 
agency care of cultural resources as dictated by the laws 
and regulations cited above, we do not think it appropriate 
that recreation and cultural resource management be consistently 
treated as similar management concerns. Although the 
preservation of some historic resources can be happily coordinated 
with interpretive/recreational use, FWS and COE are responsible 
for cultural resource Identification and protection regardless 
of recreational strategies chosen. Additionally, contrary 
to many perspectives, recreational use of hsltoric resources 
does not necessarily lead to their preservation. Hence, 

In both proposing alternatives and evaluating them, we recommend 
separate discussions of cultural resources under separate 
head i ngs. 


b) Second, the basic COE and FWS responsibilities for cultural 

resource Identification and protection cannot vary from alternati 
to alternative. They exist regardless of other management 
strategies chosen. The priorities for systematic survey and 
nomination or the forms of protection chosen may vary and 
should be discussed within each alternative, but not the primary 
responsibility. The current draft implies that more actual 
compliance work such as survey will be accomplished only with 
the proposed action alternative. 


2 


249 


page 2 

Erwin W. Steucke 


c) The discussion of the affected environment contains no consideration 
of cultural resources--ei ther historic or prehistoric. 

Commensurate with the descriptions provided for other resource 
categories in the refuge, this section should describe the 
kinds, numbers, and locations of cultural resources already 
known to exist in the area, the extent to which systematic 
inventories have been undertaken, and any summary statements 
that are professionally possible about anticipations for 
locating other cultural resources. 

We are familiar with cultural resource work and commitments being 
made in the refuge. Hence, we would urge that that work and understanding 
of cultural resource legal requirements be incorporated into this document. 

Sincerely, 


Marcel 1 a Sherfy 
Deputy SHPO 




MS/det 


Response to Montana Historical Society 


1. The FWS is in agreement that use of historic resources does not 
necessarily lead to their preservation; there is no intent to imply 
otherwise. A single heading is used to reduce the complexity and 
increase the readability of the text. 

2. It is indicated in the EIS that the action for cultural resources 
is similar for all alternatives. The FWS will comply with all 
pertinent legislation concerning cultural resources as funds and 
manpower become available. Any variations in degree between 
alternatives are reflected by these two considerations. 

3. Because of the sensitive nature of these resources, their vulner- 
ability to unauthorized collecting, and after coordination with 
your office, FWS intentionally omitted this detailed information 
from the EIS. The data are, however, available in our Lewistown 
refuge headquarters for examination by qualified individuals. 


MONTANA PUBLIC LANDS COUNCIL 

Old West Rangeland Monitoring Project 
2619 2nd Avenue N - 306 Pratt Bldg 
Billings. Montana 59101 
(406) 246-3030 


November 13, 1980 


To: Erwin W. Steucke, Area Manager 

Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th St. 

Billings, MT 59101 / 

From: C. E. Hitch A ^ I 

Montana Public Lands Council V-* O ' 

Room 306 Fratt Building 
Billings, MT 59101 

Re: Comment on Draft Environmental Impact Statement for the C. M. Russell National 

Wildlife Refuge 


I find this EIS the most difficult to comment on since the writers of the docu- 
ment seem almost totally confused. This confusion starts with the first sentence in 
the Foreword. It states the area has "suffered from a lack of comprehensive planning 
and conflicting jurisdiction". The first time I saw the area was about when it was 
designated by Roosevelt. It was in very general vise by many interests including many 1 
head of horses, cattle and sheep. Wildlife were not plentiful, and there was a lot 
of bare ground. Tour survey shows it to be 85$ to 90$ in good and excellent range 
condition (Appendix 9). I doubt if anybody will do any better to stabilize the area 
in the next 45 years. How the area has suffered I do not see. 


Paragraphs 3 and 5 of the Foreword cite the CEQ guideline. Since there have been 
several grazing reductions in the past two years "according to our plan", it is 
questioned if the guidelines are followed. There is reason to believe your action has 
already been chosen, and this entire document is a wasted paper exercise. 


Any planning effort should have qualifiable and quantifiable goals. Your state- 
ment in the Foreword (paragraph 4) shows a curious lack of both. "High quality wild- 
life habitat" would lead one to believe such was in progress until it comes to mind 
high quality habitat to the prairie dog is poor range condition and bare ground. 

High quality habitat is old diseased trees to some woodpeckers and climbing grub 
eaters. Thus you have included extreme opposites in your goal, with everything in 
between, without any limits on either from time, quality or quantity. 

A quick check of the CMR goals on page 4 does little to clarify. Eour and five 
speak of "Restore and maintain habitat" and "manage migratory bird habitats" and all 
wildlife are again in a neat little package. They are not, as I illustrated in the 
above paragraph. Number 6 speaks of the "nationally significant Missouri River 


Erwin W. Steucke 
November 13, 1980 
Page 2 

breaks ecosystem. It is not one ecosystem as your own mission states on the same 
page. It is generally thought to be a complex of associated ecosystems. 

Number 8 of your goals again resorts to more such language in "grazing compat- 
ible with wildlife and habitat goals . " Since these seem to cover anything somebody 
wants at that time and place, is it any wonder livestock interests are a bit upset 
with the F & WS? 

Number 11 is the same story all over again. You cannot define what you want 
and where you want it so, how can you "coordinate and integrate"? Even here you 
qualify with "where feasible" which long experience has taught means it won't be. 

In your Purpose and Need For Action (page 1) you quote "a local sentiment for 
more grazing." I attended most of the local meetings you mentioned and know most 
of the livestock owners that run on the CMR. I heard none of this sentiment. I 
did hear a lot of need for more grazing facilities - some fence but mostly water 
to help distriubtion problem. I also heard many people stating problems of stabil- 
ity in their livestock operation when confronted with F Sc US instant decision tech- 
nique. The economics of livestock operation nowadays requires the operator and his 
banker to be able to look ahead several years. I hope the readout of your scoping 
was more accurate in other areas, but conversations with some recreation and hunting 
interests does not so indicate. 


3 


4 


A major problem with this EIS concerns the enclosed state school and private 
lands. You admit (Page 1, 1st paragraph) that they complicate management. You list 
them under Affected Environment (Page 31)- From there on you treat Ihe whole thing 
as nothing. Under Consequences (Page 84, 3rd paragraph) you state "Grazing on State 
and private inholding would remain at present levels." That is utter nonsense. If 
they are U3ed with the allotment there is no way you can change or modify grazing on 
the CMR and not impact the grazing of these areas. You apparently show these areas 
in the total acres (Appendix 9) but then proceed as though they didn't exist in 
Appendix 5 and 10 when listing impacted AUM's and the Operations impacts. They are 
written off with a "will have to be purchased" under the no grazing alternative as 
though it would create no problem. You speak of a "willing seller basis" and 
totally ignore that the F & WS Management has almost precluded their 6ale to anybody 
else. 


Another major problem with the EIS concerns the boundary problems. It is 
written off so easily it is impossible to believe. Such statements as "Range 
improvements would be limited to 400 miles of boundary fence" (Page xi, 3rd para- 
graph) or "other portions of the boundary would be fence if problems arise" (Page 
13, Range Developments) or "A boundary fence would be constructed around the entire 
refuge" (Page 86, 2nd paragraph). These statements totally ignore the extreme diffi- 
culty and cost of fencing much of the unfenced boundary. You also ignore the very 
high maintenance cost of such fence. Elk, snow, moving earth, and storms make even 
a carefully located fence in this area a maintenance headache. Many of these boundary 
areas would be much much worse. Since they cut across the access routes for livestock 
and wildlife they would certainly create grazing problems both inside and outside the 
CMR. I find no recognition or analysis in your grazing EIS of this and the problems 
that are obvious to those who know the area. 


250 




Erwin W. Steucke 

Ervin W. Steucke 


November 13, 1980 

November 13, 1980 


Page 4 

Page 3 





It is also a ludicrous situation that you, who as an agency have stopped needed 


Another major problem with the EIS concerns the very inconsistent analysis of 



water development for a long period, should use that lack as a club to limit or rule 

10 

wildlife and their impacts. It is illustrated with prairie dogs. On page 3 you 



out livestock grazing. 


state "a specific plan for prairie dogs will be prepared" yet two pages later (page 




5, 8) you show plans for "between 5,000 and 20,000 acres" of dogtown - not very 



Another major problem of this EIS concerns the use of figures in your so-called 


definite, tirue, but much more so than any other objective. You state (Page 7, 

7 


socio-economic figures. I will leave it to experts to delve into it in depth, but 


Habitat Management) that "Prairie dog control would be considered where refuge 



it doesn't take an economist to suffer from shock at your treatment. You mention 


lands adjoin other landowners." This statement totally ignores that considering 



several times a grazing fee economic impact (page ix, last paragraph). It does not 


the given shape of the refuge and the known habit of these animals to migrate and 



take good judgement to know that the $1.89/AUM grazing fee is a very small part of 


form new towns, you do not have any dogtowns that are out of impact range of other 



the economic impacts of grazing or not grazing. There are operators who are paying 


lands . 


that much and more in taxes or interest alone. You also cite the income from the 




800 acres farmed as less than $10,000. That, gentlemen, is about $12.50 per acre; 


Another illustration of this type of analysis concerns elk. You state (page 



and if the gross is not more than that, it would not be farmed. If it is supposed 


44) "the population is at a level that can be tolerated" and (page 74) "Elk popu- 



to be the net income, it does not mean much as it is recognized that agriculture is 


lations would not change" in the proposed actions, but you call for "Improved 



a low net operation for most; but the gross is very important. As a state we run 


security cover" (page 5, 9). Why? You have one of the highest producing herds 



on it. 

11 

known; and you do not want them to increase, yet you call and plan for more pro- 





tection. That is trying to go two ways at the same time and raises questions about 

8 


Your comparison with the six county totals is probably all that was available, 


your real intentions. lou also call for lure cropping to try to decrease elk 



but it is not very indicative. These ranches who run on the CMR are not a large 


depredation (Page 11, 3rd paragraph) yet in the same paragraph you call for "coopera- 



slice of those counties. 


tive farming will be phased out". You know and the operators know this cooperative 





farming has attracted elk. What do you want to do, push them out onto private land 



Appendix Table 13-C shows a real poor use of figures. If you can get a 


and create more conflict problems? 



recreation benefit of $271,600 from no action, you should not claim $292,000 




benefit for your proposed action. The actual benefit of your proposed action 


Another major problem of this EIS concerns the use of known and not known 



is only $20,400 over doing nothing. By the same token the Intensive Management 


scientific data. It is illustrated in your many references to "ripping of dense 



Alternative is a heavy loss over what you could get by doing nothing at all. I 


clay and pan spot sites". Up to 38,000 acres are planned under the multi-use 



don't know how you arrived at those figures, but they surely don't track. 


alternative (Page 89) but some is planned and mentioned under other alternatives. 




This surprised me as I know of no long-time benefits of ripping these sites. 



It is not possible to individually take up all of the items in question in 

Finally,. I found (Page 85 ) your authority. The two personal communications deny 



this EIS. Some of these will be used to show my problem 

the conclusions. Ross Wight's work and results also deny such conclusions. You 




have confused spiking, which is used on club moss and gramma areas and usually a 

9 


Page 8 Range Improvements; Your statement would lead the public to believe 

12 

silty site to break a vegetative barrier and allow a vegetative change. Ross 



there has been some done in recent years. No operators can point to any. Ii 

Wight did his work on dense clay and pan spot sites, but it was furrows that gave 




the benefit. Ripping, and you define it correctly in the glossary, had no lasting 



Page 9 overview ( 4 ) ; This statement tied to your proposed action is an out- 

effect. Furrows with a certain capacity gave the results of about 2 \ times increase 



right fraud. You have raised questions on every signed off grazing plan in which 

in production. The shape of the furrows was not important if they held the water. 



you are involved. Your mandate and goals go too many different directions at once 

Another factor shown in Wight's work that you apparently didn't read concerned the 



to agree to any grazing plan. 

dense clay site. The area in question produced so little to start with that the 




increase did not give a significant yield. In other words, it did not pay. 



Page 9 General; Ownership of land purchased by the COE is not in question in 




most of the courthouses of the counties. Only Big Brothers seems to have question 

13 

Another such use of scientific data came into your preparation shown in Appendix 



of what was purchased. 


15. Suitability of an area for range use has been debated for a long time. You cite 




on page 198 many of the variables and why it is not possible to book such a factor. 



Page 24 No Grazing-Habitat Management; A non-grazing treatment would present 


Then you, who have been unable to define your own goals in any recognizable quantity, 



a real wildfire situation, .which was not even mentioned. Having seen a couple fires 


on the basis of some wildlife observation, develop a table to two decimal places 



in this area, any assumption of control is questionable. Given a dry spell and wind 

14 

that rules areas not suitable for cow use that cows have used for most of 100 years. 



(not unusual in this area) and adding that type of fuel supply to this rough area, 




is a near invite for a disaster. 



Erwin W. Steucke 
November 13, 1980 
Page 5 


Page 41, 2nd paragraph; Flooding and ice jams were not originated with Fort 
Peck. Having seen large ice cakes in the town of Loma and a 12-14 inch tree 
chewed off at the mouth of Eagle Creek, I contend your entire Missouri River plan 
should recognize this fact of life. 


15 


Page 51, Table 7 - Tour mileage figures looked a bit odd so I checked. A 
straight line from the comer (SW) to the named area shows Canyon Ferry, Freezeout, 
Holter, and Hauser all much closer to 150 than the figures given. Deadman Basin is 
90, not 80. To use this mileage a helicopter would be required, and they are not 
in frequent RV use. Not only are the figures in error, but what are you trying to 
show? It has nothing to do with the way people travel and, even if they were 
accurate, they mean little to the people who use the area for recreation. 


16 


Page 55 2nd paragraph; This is just not a fact as there are two projects 
proposed in the Circle area on which there is a lot of information, and it could 
be used. Certainly it would contribute to recreation demand in the area. If they 
go in is questionable, but the proposals are well drawn out and discussed through- 
out the area; and their impact on the EIS area would be substantial. 


17 


Page 55 last line and 1st line on page 56; The injection of money by recreation 
visitors is subject to two questions. First, many such visitors bring a lot of the 
food and housing with them, so the impacts are definitely not local. Second, there 
has been a substantial change in the amount of these long-range visits since gas 
prices went up. 


18 


Page 64 2nd paragraph; Your comments on sagebrush are a soil-site difference. I 

Big sagebrush prefers heavy soil areas. Silver sage prefers silty and overflow J19 

sites. This will not change. 


Page 64 3rd paragraph; You again state the herd size would remain as is. It 
is one of the highest in the state for reproduction. It got there with the roads 
and "lack of security cover" and seems to thrive. What direction are you really 
trying to go? 


20 


Page 71 Wildlife Habitat - Range Resources; These prairie dogs have been 
expanding into adjacent areas for 20 years, but so far you have done nothing but 1 21 
question the "necessary control measures". 


Page 170 Appendix 8 2nd paragraph; You went to considerable expense to hire 
four very qualified and experienced range men to run a site and condition survey. 
You show it In Appendix 9 but otherwise bypass and ignore it and their recommenda- 
tions. Then here you question if they even knew what they were doing. Every one 
of these men has more time in range than the entire staff at Lewistown. This re- 
flects rather heavily on the quality of crew that wrote this document. Cry babies 
they are, but qualified is questionable. 

This comment could go on for a real long time as there are many items that 
should be questioned. I will not, however, and will summarize. 

1. You were given an area by Congress for administration, but you spend much 
time crying because you didn't get the whole cake. The COE were there before you 


22 


Erwin W. Steucke 
November 13, 1980 
Page 6 

and have assigned responsibilities and action that if they conflict with yours 
should be recognized. There is no call for the tears you shed in this. The same 
can be said for the state school lands and the private lands. It also applies to 
State Park right-of-ways, road right-of-ways and cabin area right-of-ways. 

2. Your goals are not measureable for comparison so needed in an EIS. 

3. Your scoping of problems leaves much to be desired. 

4. You did not recognize and analyze the grazing impacts of your proposed 
action on enclosed lands. 

5. You did not recognize and analyze the grazing impacts of the boundary 
problems . 

6. There are gross Inconsistencies in your discussion of wildlife problems. 

7. Your use of research and scientific data is poor. 

8. Your use of socio-economic impacts is questionable. 

With all this, I would question if this document should even be considered a 
grazing Environmental Impact Statement. 


CEH:da 

cc : Advisory Council 

Senator Melcher 
Senator Baucus 
Representative Marlenee 


251 


Response to Montana Public Lands Council 


1. Inasmuch as CMR is a national wildlife refuge, the management 
priorities are for wildlife, and range condition cannot be equated 
with wildlife habitat. 

2. Over the past two years, the FWS has taken the opportunity to place 
portions of livestock grazing in a non-use status in those areas 
affected by ranches that have sold. In all cases, the amount of 
grazing remaining active, and the amount placed in non-use were 
based upon professional opinion using the best site specific data 
available at that time. The Proposed Action will modify these 
interim decisions. 

3. A goal is normally expressed as a broad, general statement is 
usually not quantifiable, and usually has no specific date by which 
it is to be completed. An objective is a clear and specific state- 
ment of planned results to be achieved within a stated time period. 

4. One of the mitigating factors considered in the Proposed Action is 
the ability to lend a stability factor to the permittee operation 
utilizing AUMs on CMR. 

5. Recognition of state and private inholdings was included throughout 
the planning process. Although changes will be made in livestock 
AUMs under several of the alternatives, no changes are planned by 
FWS for state and private inholdings. 

6. As ranchers know, a fence is expensive to install and maintain, but 
is frequently necessary for proper land management. The FWS recog- 
nizes these facts also. 

7. The FWS acknowledges that prairie dogs establish new towns through 
migration to suitable habitat each spring. The Animal Damage 
Control program of the FWS will assist the private landowner in 
control of unwanted dog towns on private land. 

8. Elimination of the farming program along the Missouri River in 
Phillips and Fergus counties will increase the amount of habitat 
for native wildlife. Lure crop farming in Valley County would be 
an attempt to alleviate or minimize elk depredations on agricul- 
tural crops. Improved security cover will help to hold elk on the 
refuge. 

9. After reviewing public comment and reexamining pertinent research, 
the FWS has concluded that soil ripping is not a viable manipula- 
tive technique for habitat management on CMR. All references to 
ripping have been deleted from the text for the Proposed Action. 


10. The range suitability criteria developed by the FWS were derived 
from the most applicable information available. The FWS acknow- 
ledges that such criteria are necessarily broad, and within groups 
of animals (domestic livestock), there is individual behavior 
contrary to the norm. 

11. Your concern over the $1.89 on AUM is correct in that the $1.89 fee 
does not reflect the value of the AUM to the ranch operation. Thi6 
has been corrected by adopting a linear programming (LP) approach 
to estimating the financial impacts to the rancher. The LP analy- 
sis estimates the change in gross income associated with a change 
in CMR AUMs. The LP measures changes in rancher cash expenditures, 
labor inputs, returns to investment, and beef cow inventories. The 
analysis does this using an average ranch budget for ranches of 
different ranch sizes classes. These budgets take into account 
numerous factors including seasons of use and differences in depend- 
encies. This approach tailors the analysis to the regions and 
ranches by reviewing the representative rancher panel for the EIS 
area. In this case, the value per AUM was $12.87. Thi6 technique 
is being applied to analyze similar grazing actions for BLM. The 
National Cattlemen's Association and Public Lands Council support 
this approach assessment. See Appendix 10 for example inputs and 
outputs. 

The entire economic evaluation has been revised as have Appendices 
10 and 13. 

12. A number of developments including stock pond renovation have been 
completed in recent years. 

13. This statement has been clarified. 

14. The FWS acknowledges that Alternative E (No Grazing) would increase 
the fuel load on a site specific basis. This would Increase the 
occurrence of wildfire on the refuge. 

15. The text has been amended. 

16. The table shows that within a 150-mile radius of CMR, from which 
about 75 percent of the visitation to the refuge originates, there 
are a number of other recreation areas with comparable resource 
values that attract visitors away from the refuge. 

17. The potential Impacts of such projects on recreational use on the 
CMR has been recognized in the DEIS, but such impacts are not 
quantifiable; since these projects are in the proposal stage only, 
they are beyond the scope of document. 

18. Both of these have been taken into consideration in the preparation 
of recreation estimates and economic impacts. 


19. The FWS agrees that silver sagebrush and big sagebrush prefer 
different soil types. 

20. Since CMR i6 a national wildlife refuge, one of its purposes is to 
provide high quality wildlife habitat. 

21. The Animal Damage Control staff of the FWS provides control assis- 
tance to requests from private landowners. 

22. A range site and condition survey is Just that; it does not contain 
recommendations. Any recommendations are derived later based upon 
that survey and the purpose for which an area is to be used. 



COLLEGE OF LETTERS & SCIENCE 


DEPARTMENT OF BIOLOGY 

MONTANA STATE UNIVERSITY BOZEMAN 59717 


3 December 1980 


Mr. Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, MT 59101 

Dear Mr. Steucke: 


Several members of our wildlife staff have been involved in 
studies and management of wildlife on and in the vicinity of the Charles 
M. Russell National Wildlife Refuge. Thus, we have direct interest in 
future management programs for wildlife populations and habitats on that 
area. We have reviewed the draft management plant and environmental impact 
statement and offer the following comments. 

1. In general, we found the plan difficult to evaluate in terms of 
potential impacts and/or benefits on wildlife populations and habitats. 
Aside from some specific changes in livestock grazing, the plan is 
extremely general. It does not clearly spell out what will be done where, 
what priorities are, or how proposed actions will be followed up. 


2. Paragraph 5, under Purpose and Needs, is bewildering. Was not 
the purpose of studies leading up to this plan to evaluate the status 
of resources on the CMRNWR? Is the present document not also a "master 
plan" or a summary of that plan? This discussion would place development 
or specific wildlife management programs somewhere in the future. 


3. We have reservations about the extent to which the plan and EIS 
focuses on livestock grazing. Indeed, it appears that the document is 
primarily a livestock grazing-range management plan in which wildlife 
management problems and needs or objectives are secondary. We recognize 
that grazing problems exist and concur that some changes in livestock 
grazing policies and practices would benefit wildlife and may be necessary. 
However, such changes might be more appropriately based on specific wild- 
life needs and management objectives. Would it not have been more consistent 
with mission and goals of CMRNWR to have developed this plan around those 
needs and objectives and fit livestock grazing into the plan, when and where 
it would enhance wildlife values or where no conflict is likely to occur? 

The present document suggests that the opposite will occur; i.e., under 
Alternative B. Proposed Action, a (wildlife?) habitat management plan will 
be developed by 1985 for each grazing allotmen t . 


3 


TtUPHONE (406)994 4548 


252 


4. Wildlife, range and recreation objectives listed in the plan 
include no supporting rationale. Thus, they must be accepted at face 
value and cannot be evaluated in terms of their relationship to specific 
problems and needs or opportunities and constraints that may exist generally 
or on specific portions of the area. Also, in some cases, objectives appear 
to be inconsistent with one another, with existing knowledge, or with state- 
ments made elswhere in the plan. 


5. Wildlife management, especially habitat management, objectives 
take the view that, in some general manner (not indicated), habitat can 
or will be improved everywhere for everything, including several species 
of extremely diverse and conflicting habitat/environmental requirements. 
Without more specific details as to what will be done where, such objectives 
lack credibility. Some are inconsistent with present conditions or with 
potential of the area as a whole. For example. Objective 7, listing a goal 
of 10 mule deer/mi^ has now been exceeded on some parts of the area. It is 
unlikely that some other portions will ever attain such density. 

6. Wildlife objectives to not include continued assessment of resource 
characteristics and trends. Such assessment would seem essential for 
on-going evaluation of management needs and opportunities in a changing 
environment. Clearly, the intent of the plan is "to change wildlife 
environments through alteration of grazing and habitat improvements." 


7. Apparently, livestock management under proposed action will be 
based on forage allocation determined by livestock distribution and behavior 
in relation to distance from water and slope. These criteria will be 
applied "across the board." Such an approach does not address specific needs 
or habitat requirements of all wildlife species on the area, not does it 
recognize that both these needs and the potential for future livestock 
grazing may vary greatly from place to place and from time to time across 
the area. A variety of grazing prescriptions involving different stocking 
levels, different times or seasons of grazing, different grazing systems, 
and different breeds or classes of livestock may be necessary to meet specific 
wildlife and other management needs and objectives. 


8. Alternatives A, D, and E would require major changes in the status 
of CMR or policies governing the National Wildlife Refuge System. At present 
they would have to be considered illegal. Yet, much discussion is directed 
to these alternatives that divert attention from Alternatives B and C that 
relate more closely to the mission and goals of CMRNWR. They may also foster 
additional confusion and misunderstanding of mission and goals. On the other 
hand, Alternatives B and C, the Proposed Action and Intensive Wildlife Manage- 
ment plans, probably represent only a part of a broad spectrum of potential 
wildlife management alternatives that might be employed or pursued within 
the CMR mission and goals statements. 


8 


9. Numerous questions can be raised concerning specific management 
prescriptions under tha various alternatives. At least some seem to reflect |3 

general "pie-in-the sky" planning and not reflect careful assessment of 1 


management needs or opportunities and constraints. Under proposed range 
developments, new fences, water developments and soil ripping are indicated. 

No specific details are given, nor is there any Indication of how these 
actions would enhance watershed, wildlife or recreational values and programs. 


10. The assessment of wildlife habitat-range resources seems to 
have been undertaken without consideration of how those resources are used 
and meet specific needs of individual wildlife species. We consider such 
assessment minimal and possibly meaningless. It does not provide basis for 
development of sound, effective management actions. Rather, assessment 
of grazing-habitat management problems and needs should address the requirements 
of individual species and how each is distributed on and uses the area, seasonally 
or yearlong. It is to state that a particular range-habitat resource is lack- 
ing or limiting in a certain area. Yet, it is an entirely different matter 
to determine whether anything could be done about it in view of environmental 
constraints. Presumptions of need and/or benefit based on general assessments 
may not be valid. 


We fully support your effort to develop sound, aggressive management 
of wildlife populations and habitats and other resources on the CMRNWR. 

However, we question whether the present proposals fully address basic problems 
and needs or all possible management alternatives. If the present draft 
plan and EIS is revised, we hope that it would include more of the "master 
plan" for management. Wildlife management and other resource goals and 
objectives should be carefully evaluated and set forth more completely and 
prominently. Priorities should also be established. Alternatives should 
address both basic goals and objectives and priorities. 


If necessary we would be happy to provide further explanation of our 
views and comments. 



Professor of Wildlife Management 



Assistant Professor of Wildlife Management 


Response to Montana State University 


1. The level of detail requested here is more appropriate to a master 
plan and is available for review at the refuge office in Lewistown. 

2. The planning process is summarized in Appendix lb. The EIS is an 
assessment of the Impacts resulting from the Proposed Action and 
other alternatives on specific environmental parameters. Develop- 
ment, specific management, and implementation will be initiated 
upon finalization of the EIS and fine tuning of the master plan. 

3. Please see Appendix lb which summarized the planning process and 
rationale . 

4. The objectives are derived from the mission statement, goals, and 
purposes for CMR, the national wildlife refuge system, and the FWS. 

5. Vegetational types and landforms are inherently diverse on CMR, and 
the maintenance of these communities will provide wildlife habitat 
for wildlife species with diverse habitat requirements. 

Specific applications to meet specific wildlife needs on specific 
areas will be addressed in detailed habitat management plans after 
the final EIS is approved. The EIS generalizes the wildlife manage- 
ment plan for the refuge as a whole under each alternative. 

6. It is correct that the intent is to Improve wildlife habitat. All 
alternatives do include plans for a continued evaluation of plan 
success. 

7. Forage allocation will be based on prescription treatment by allot- 
ment relative to wildlife habitat needs. 

8. Regulations require the examination of alternatives "not within the 
jurisdiction of the lead agency." 

9. The level of detail of the EIS Is not appropriate for the discussion 
of specific management prescriptions (i.e. each new fence, each 
range development, etc.). This Information is more suited to the 
master plan which will be finalized after a decision is made on the 
EIS alternatives. 

10. The Habitat Evaluation Procedures used by FWS evaluate habitat 
components in relation to individual species. From this evalua- 
tion, habitat components that are lacking can be specifically 
addressed in management actions, dependent upon the capability of 
sites to correct habitat deficiencies. 



8 

Jj'hitc of Montana 

Office of Cljc (Sobcntor 


^jdclnui 591501 


THOMAS L JUDGE 

GOVERNOR 


December 8, 1980 


Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
Billings, Montana 59101 

Dear Mr. Steucke: 


I am pleased to provide you with comments on the Charles M. Russell 
National Wildlife Refuge Management Plan Draft Environmental Impact 
Statement. 


There are three observations that consistently surface upon re- 
viewing the draft EIS and your proposed alternative: 


1. The orooosal to increase wildlife population to some stated 

level seems unrealistic; and the EIS contains no proposed plan II 

of action on how this may even be accomplished. 0 


2. The recommendation to reduce livestock grazing by one-third 
appears highly questionable since nearly all of the grazing 
allotments are in good to excellent condition. Reducing 
livestock grazing will not necessarily enhance a different 
veqatative species for other wildlife species. 


3. The C. M. Russell Wildlife range is situated within a mixture 
of land ownership including state and private. Wildlife 
populations benefit from off-refuge use as well as on. The 
C.M. Russell refuge is not an island! Decisions on the refuqe impact 
the entire ecosystem in the area. It is imperative that a management 
plan be developed cooperatively with state and private users. 


Given the absence of any information on how various objectives, goals, 
and populations are going to be carried out, I am recommending that the EIS 
be redrafted to reflect the aforementioned points as well as those issues 
raised by the various agencies. 


I have enclosed comments from four state agencies for your information. 
I trust that you will give them serious consideration and Incorporate them 
In your final analysis. 

Sincerely, 


Thomas l. judge 

Governor 


263 



STATE OF nOXTAXA 


iit;r.vKT?ii.>T op 


f.sr. 


HSByUTD (i.tjlh' 


Helena, Montana 59620 
December 3, 1980 




Lt. Governor Ted Schwinden 
Room 207 

Capitol Building 
Helena, Montana 59620 


Dear Lt. Governor Schwinden: 


We have reviewed the Draft Environmental Impact Statement - Management of 
Charles M. Russell National Wildlife Refuge. 

There is no supporting rationale for the goals, wildlife objectives, range 
objectives, recreation objectives and management alternatives presented in 
the Draft Environmental Impact Statement. 

Thus, they must be accepted at face value and cannot be evaluated in terms 
of problems, needs, opportunities and environmental constraints. Also, no 
priorities are considered. In some cases, objectives may be or seem incon- 
sistent with what is now known. For example, population goals for deer. a 

sharptail, and elk are general extensions of data for local areas and cannot ** 

be applied throughout the refuge. The failure of past efforts to introduce 
bighorns should cast some doubt on that objective. Some objectives seem 
inconsistent with earlier statements (e.g. , the objective to improve climax 
range condition (p.5), contradicts an earlier statement (p.ix), that climax 
vegetation is indicated to be predominantly in good condition). 

There is a lack of information and/or detail to explain or illustrate how I 
the various objectives, goals and accomplishments are actually going to be 15 
carried out. 


Wildlife management objectives, and especially those dealing with wildlife 
habitat management, take the view apparently that, in some general manner 
(not indicated) habitat can be improved for everything including several 
species of extremely diverse and conflicting habitat/environmental require- 
ments. Without more specific details of what will be done where, such 
objectives are meaningless and without credibility. Some are inconsistent 
with present conditions; (e.g., objective 7, listing a goal of 10 mule 
deer/rai2. Present population on some of the area now exceed that; some 
other areas will never attain it). 


6 


The alternative action/manageraent plans are all very general and lack 
specific details as to precisely what each would mean in terms of meeting 
the mission and goals of CMR and wildlife, range and recreational objec- 
tives; how and where improvements or management actions would be carried 


Lt. Governor Ted Schwinden 
Page 2 

December 3, 1980 


out; and how these improvements or actions would be evaluated. All begin 
with and focus heavily on livestock-range management rather than meeting 
specific wildlife/wildlife habitat management needs and objectives. Three 
of the five alternatives call for reduction or elimination of livestock 
grazing as a first step and/or a major part of future management. While 
we have no quarrel with such reductions, per se, the approach may be and 
probably should be widely questioned. 

To imply that any AUM taken away from livestock will automatically be used 
as food by "wildlife" would be difficult if not impossible to demonstrate. 

Most of the AUM calculations and estimates are based on grass and grass-like 
plants, not the total quantity of vegetation (forbs, brush, etc.). How much 
value is 15,000 AUM’s of grass vegetation as food (p. 19) for antelope and 
deer? This point is not addressed in the EIS. 

Under Alternative B, the proposed action, a habitat management plan is to be 
developed by 1985 for each grazing allotment. Again, this seems to put 
livestock before wildlife. It would seem more correct or logical in view of 
the mission and goals of CMR to put the needs of wildlife and their habitats 
first. Such an approach would entail assessing population and habitat 
management needs and opportunities or constraints, and then developing a 
management plan for each that could include a livestock grazing allotment 
or plan! Lacking this basic assessment of wildlife population/habitat units 
and/or precise information on how various habitat/environmental attributes meet 
the seasonal or yearlong requirements of various individual species, the 
general guidelines presented for habitat management probably are invalid. 

The proposed burning, planting, soil ripping, and plowing (farming) projects 
are not compatible with maintenance of wildlife habitat and the naturalness 
of the area that the U.S. Fish and Wildlife Service wishes to promote. 

Virtually nowhere in the literature is the planting of browse or brush cover 
deemed very successful for the improvement of wildlife habitat. 

The repeated reference to introducing more bighorn sheep, plus bison, fox, 
ferrets, falcons, and the reference to additional goose pens and wildlife 
pastures is contrary to the statement in the Forward which says "Because 

habitat is the key to wildlife abundance, this document emphasizes 

habitat. . .rather than. .. populations or densities." The concept of intro- 
ducing wildlife onto the refuge and the wildlife pen/pasture program gives 
the entire Charles M. Russell National Wildlife Refuge a "zoo-like" air 
rather chan a "natural-like" setting. 

There are some rather vague references as to exactly what the status and 
future of hunting is or is going to be. Will there have to be some pre- 
determined level or density of certain wildlife (sharptail, deer, elk, etc.) 
before hunting is allowed? The wildlife objectives are about as "heavy" 

coward densities as it is to habitat again a direct contradiction of lines 

14, 15 & 16 in the Forward! 


7 


8 


10 


12 


Lt . Governor Ted Schwinden 
Page 3 

December 3, 1980 


The entire EIS implies that CMR-NVR is somewhat of an "ecological island" 
and that accomplishments in any of the alternatives can be carried out or 
attained without sufficient regard to extensions of ecosystems outside the 
CMR-NWR! 


The Montana Department of Fish, Wildlife, and Parks cannot support, as 
presented, any one of the alternatives or even the CMR goals, wildlife ob- 
jectives, range objectives and recreation objectives without some explanation 
and detail as to exactly how they are to be attained. 


We suggest the EIS be revised and reissued along with the plan to provide 
the necessary rationale for the EIS. 


Sincerely 


y 


Orville W. Lewis 
Acting Director 


JLErmk 


DEPARTMENT OF STATE LANDS 



December 1, 1980 


CAPITOL STATION 


HELENA MONTANA 59601 


MEMORANDUM 


TO: 

FROM: 

RE: 


Governor Elect Schwinden 


Jr. , Commissioner 


DSL Comments to Charles M. Russell 


o 


Natural Wildlife Range Draft EIS 


The following coimients are offered by the Department to be incorporated into 
state’s comments. The present CMRNWR AUM allocation for livestock is not excessive. 


Stock distribution is a problem which could be alleviated by water developments 
where compatible with wildlife habitat. The range is currently in good to excellent 
condition and proper distribution can increase forage capacity as well as wildlife 
habitat. 


I" 


It is in the best interest of the school trust, at this time, to continue the 
policy of prairie dog control by lessees. The DSL will not allow uncontrolled ex- 
pansion of prairie dog towns on state lands. The EIS is unclear on the extent of the 
proposed prairie dog habitat and the time of introduction of the blackfooted ferret. 


h 


Fencing is an issue that must be studied closely. We are fully aware that fenc- 
ing is a hinderance to wildlife, especially to migratory ungulates. However, well 
planned fences can be used as an excellent management tool. We are strongly opposed 
to fencing of the refuge boundary, but where fencing can enhance management and bring 
about rapid upward trends in range condition in specified areas.it should be given 
utmost consideration. 

Domestic livestock grazing has been a part of the Missouri River Breaks natural 
ecosystem for over 100 years. The benefits of well managed grazing practices are 
numerous to an ecosystem and are evident on the CMR. The Fish and Wildlife Service 
has accepted the DSL 1979 range survey and the resulting stocking rate for each tract 
of state land on the refuge. We have no particular problem with coordinating the 
season of use in individual grazing management plans where DSL, private operators and 
the Fish and Wildlife Service can agree. 

We feel it would be in the best Interest of both DSL and CMRNWR if a Memorandum I 
of Understanding was developed and signed by both agencies which would outline and |15 
delineate livestock grazing policies for those trust lands within the refuge boundary. I 




254 


Memo to Governor Elect Schwinden 
Page 2 

December 1, 1980 


The CMR EIS is vague on the proposal to dramatically increase the deer and elk 
populations. We are aware of the problems and the concern of private operators who 
border the refuge. We will but mention this concern as it is apparent that the 
Department of Fish, Wildlife & Parks will address this issue. 

The Department favors the continuation of properly managed agricultural prac- 
tices on the CMR. The desire to return the range to a natural setting does not out- 
weigh the benefits to wildlife provided by these areas. 

Hone of the suggested alternatives are acceptable to the Department. It is 
difficult to make specific comments on the EIS because no specific proposals are made. 
Because many of the state's concerns will focus on the habitat management plans yet to 
be formulated, it is imperative that the state and local ranchers be actively involved 
in the development of such plans. At that time the state's positions on water develop- 
ments, prairie dog towns, management fencing, etc., can be more clearly defined. 


cw 


MONTANA DEPARTMENT OF LIVESTOCK 



I 


Ted Schwinden, Lt. Governor 
Room 207, State Capitol 
Helena, Montana 59601 

SUBJ : C. M. Russell National Wildlife Refuge — Draft EIS 

Dear Ted: 


We have reviewed the draft environmental impact statement concerning the 
Charles M. Russell National Wildlife Refuge. Of the approximate 856,000 
land acres, 90% is under livestock grazing. There are 60,108 AUMs allotted 
on the GMR. Formal range surveys conducted under private contract and by 
range scientists of the U.S. Fish & Wildlife Service have concluded that 
92% of the range within the grazing allotments are in excellent to good 
condition. Only 1% of the range for livestock grazing is in poor condition 
and the USFWS has recognized in the EIS that this condition was caused by 
prairie dogs. 


Eighty-seven ranchers run livestock in these allotments. No mention is 
made of the remaining 10% of land acres not grazed by livestock except that 
they are generally in excellent condition. No formal range surveys for 
these areas are reported. Under the draft EIS, a 1/3 cut in AUMs is recom- 
mended for providing additional nesting and hiding cover for upland game 
birds and additional forage for wildlife (primarily deer and elk) . 


17 


The results of the 1/3 cut in AUMs, as expressed in the EIS, would have high 
adverse impacts on six livestock operators and may result in forcing these 
ranchers out of business. Other factors such as permittee indebtedness, 
other agricultural holdings, and nonfarm incomes are also mentioned. Taking 
these factors into consideration, an even greater number of operators could 
suffer high adverse impacts and be forced out of the livestock business than 
anticipated in the EIS. The economic analysis does not take into account 
the revenue derived by livestock earnings from the CMR, and more importantly , 
the money spent by livestock producers in the local communities. 


16 


recognize the entir 


One need read no further them the Forward in the EIS 

document is based upon the emphasis of habitat quantity and quality for 
wildlife rather than animal populations or densities. Establishment of high 
quality wildlife habitat to provide adequate populations of wildlife species 
within constraints imposed by droughts, severe weather, disease, and other 
variables which are largely uncontrollable is emphasized. 


Since, an objective for CMR will be to provide 10 deer per square mile and 
2.5 elk per square mile by restricting 1/3 of the AUMs for livestock, how 
does the CMR propose to control these large populations of deer and elk 
from depredating upon private land holdings, both within the refuge and 
those on its exterior? Attempting to accomplish this objective will have 
a negative impact on CMR's neighbors. 

The primary emphasis of the EIS seems to be plant management for develop- 
ing habitat quality. The whole aspect of wildlife management dealing with 
field rodent and predator damage control is not addressed. Acknowledgment 
of range improvement by livestock producers for the benefit of wildlife on 
the CMR has neither been recognized nor given attention in this draft EIS. 


18 


20 


The EIS is very general in nature, very philosophical, and idealistic con- 
cerning wildlife management with complete disregard for neighbors. The 
realistic approach of recognizing that 92% of the grazing land in livestock 
allotments is already in excellent to good condition is a "feather in the 
hat for livestock producers who have historically worked to improve the 
CMR - It is our recommendation the CMR National Wildlife Refuge should 
continue to be managed under the multiple use concept . Farmers and ranchers 
in the area, plus our own state departments and the U.S. Fish & Wildlife 
Service must learn to work together through unit plans for the benefit of 
wildlife, domestic livestock, and man. 

Sincerely, 

J?. 


Robert G. Barthelmess, Chairman 
Board of Livestock 


RGB : KS : cmvj^L- 
cc: /Keith Kelly 


Proposed DNRC Comment on Draft Env 1 ronmenta I Impact Statement 
Charles M. Russell National Wildlife Refuge 

Environmental impact is judged by what will happen to the natural 
resources of soil, water, vegetation, and wildlife as a result of the 
activities of man and nature. In the case of the Russell Game Range 
the federal government has decreed man's activities be predominantly 
that of management for certain wildlife values. First consideration 
Is given to the Impact on the soil, water, and vegetation. Prairie 
dogs will have the most noticeable adverse effect on the soil and 
vegetation If not carefully controlled. Other proposed wildlife 
will have lesser effect on the soil, water, and vegetative resources. 

If carefully managed. 

Because habitat Is recognized as the key to wildlife abundance 
and Inasmuch as it Is the purpose of the Russell Game Range to emphasize 
habitat quality and quantity rather than wild animal population and 
densities, this situation occurs now with generally good to excellent 
condition range. 

It seems that the management of the Russell Game Range Is in an 
excellent position to demonstrate to the public, to public land managers, 
and most Importantly to the private sector, the advantages of multiple 
use management on all grazing lands, public and private, within Montana, 
and what It takes to do this to produce wildlife on all lands. 

The Russell Game Range Is situated within and without a mixture of 
Intermingled land ownerships. The local economy as well as statewide 
Is dependent on the domestic livestock as well as the wildlife values. 

It Is almost Impossible to separate the management of each. One Impacts 
very much on the other socially, economically, environmentally, and 
politically. These values must be more realistically evaluated to what 


255 


RE: C. M. Russell Game Retuge 


Is acceptable. To do this It Is recommended a strong note of 
cooperation be addressed with local ranchers, sportsmen and organ- 
izations. 

It Is the recommendation of the Conservation Districts Division 
of the DNRC that the management alternative selected be as near the 
multiple use concept as possible. 

It Is further recommended that local Cooperative State Grazing 
Districts and Conservation Districts establish a closer working 
relationship on these matters. 

The Montana Rangeland Resource Coordination Act is a law which 
Includes a number of agencies and organizations Including the Fish and 
Wildlife Service to resolve management Issues. We would recommend 
further review under this means. 

We are Impressed with the recommendation of local ranchers in 
the area that recommend the Gus Hormay rest rotation system. This Is 
a plus for good range management for domestic and wildlife purposes 
and will go far toward being acceptable socially and economically, as 
well as envi ronmental ly. 


21 



Response to the State of Montana 


1. The EIS is proposing the improvement and maintenance of wildlife 
habitat capable of supporting an average of 10 deer and 2.5 elk/ 
sq.mi. on suitable habitat. Improvement of these habitats will be 
accomplished by grazing reductions, prescribed burning, and other 
management techniques described in the text. 

2. We must reiterate that range condition and the condition of wild- 
life habitat are not synonymous. 

3. We agree with your entire paragraph. See CMR goal #11 and the 
Foreword. 

4. According to CEQ Guidelines (Sec. 1502.1 Regulations for Implement- 
ing the provisions of the National Environmental Policy Act), the 
purpose of an EIS is to discuss the impacts on the environment of 
various alternatives and methods of reaching or attaining certain 
goals and objectives, not a discussion of the rationale supporting 
those goals and objectives. Such rationale comes from legislation 
and Service policy and is contained in program management documents 
on file in the FWS Lewistown office. 

The goals and objectives are generally in priority order. Also see 
Appendix lb. 

Population goals for various species are, as you say, extensions of 
data for local areas. These data are not intended to be extended 
throughout the refuge, but to areas of similar habitats and poten- 
tials. 

Further attempts to introduce bighorn sheep have been carefully 
considered and discussed with the Montana Department of Fish, 
Wildlife, and Parks; the concensus being that it is a worthy ob- 
jective and should be attempted. See statement on page 45 concerning 
1980 bighorn sheep introduction. 

See amended range objective If 1, page 5. 

5. Detailed plans on how FWS goals and objectives are going to be 
accomplished are beyond the scope of an EIS. These will be spelled 
out in unit habitat management plans to be developed at a later 
date (see also Appendix lb) . 

6. Objective No. 7 refers to an average of 10 mule deer/mi2 in good 
mule deer habitat. FWS recognizes that some areas will support 
more individual animals/mi2 and some less (see page 3, paragraph 
6). The objectives do not imply that habitat for every species 
will be improved over all the refuge. Habitat Evaluation Procedure 
(HEP) criteria indicate that by managing in accordance with the 
Proposed Action, habitat conditions will evolve that will support 
objective levels of wildlife. 


7. Highly detailed plans on how FWS meets it9 mission, goals, and 
objectives are beyond the scope of an EIS (see answer #4 above). 
These details will be spelled out in habitat management plans to be 
developed later. Of the several factors under FWS control which 
affect habitat on CMR, livestock probably has the greatest Impact. 
See revised Foreword, Appendix lb, and Appendix 15 for approach 
used . 

8. There is no intention in the EIS to infer that an AUM taken away 
frcro livestock will automatically be eaten by wildlife. The EIS 
deals with total wildlife habitat, not Just food (AUMs) . 

The total habitat requirements include soil productivity, residual 
cover, interspecific strife between wildlife species, and between 
wildlife and nonwildlife species, escape cover, etc.; thus, there 
is no point in assessing 15,000 AUMs of grass as food for antelope 
and deer. 

9. We agree with your comment that wildlife should come first, and 
intend to manage CMR that way. Note that the plans to be developed 
are habl tat management plans. These plans will be based on HEP 
criteria (Appendix 2), which spell out the needs of wildlife by 
species. These habitat plans will be developed on each grazing 
allotment (or combination of similar allotments) as these are 
already established, well-defined, geographical areas. The purpose 
of the habitat plans will be to provide for the year-long require- 
ments of wildlife in one or more allotments. 

10. FWS generally agrees with your statement. All references in the 
Proposed Action to ripping have been eliminated in the final EIS. 
All farming along the upper reaches of the Missouri River will be 
phased out. Shrub planting will only be used in rare Instances to 
establish seed sources. Some burning is proposed to help establish 
shrubs. 

11. FWS agrees and that is why the only introductions in the Proposed 
Action alternative are for peregrine falcons, black-footed ferrets, 
swift fox, and bighorn sheep, all indigenous species to north 
central Montana. None of these will be in pens, and all releases 
will be to either reintroduce a species not now present on the area 
or to bolster a flagging population. 

12. Providing public hunting is part of goal number 9, page 4 and is 
again provided for under Recreational Objective number 2 on page 6. 
Public hunting is again stated as an appropriate use under number 

5 on page 9. Obviously, population levels for a certain species 
will have to be at a level that provides a harvestable surplus for 
that species in order to permit hunting. Listing that level for 
each species is beyond the scope of this document. 


We agree with your observation that the EIS refers to habitat in 
the Foreword and other places, but the objectives list numbers of 
wildlife. Numbers were essential for certain species such as 
peregrine falcons. Also, the habitat that will support say 10 
deer/sq.mi. is an indicator of habitat that will support numerous 
other wildlife species without listing a certain number for each 
species . 

In general , the EIS deals with habitat, but references are also 
made to specific wildlife numbers, usually as an indicator of the 
quality of the habitat desired. 

13. The decision to manage in a "generally natural setting" is in 
accordance with the FWS legislative mandates and policies and 
precluded further water development except where specifically 
mentioned in the text. Further, in examination of HEP values 
compiled on allotments on the refuge, it has been concluded that 
additional water development would be detrimental to most wildlife 
species in that it would distribute livestock into areas now used 
almost exclusively by wildlife and that are needed by wildlife. 

14. Please see revised Wildlife Objective number 8, page 5, which 
states that between 5,000 and 10,000 acres of prairie dogs will be 
maintained. Objective number 2, same page, says that ferrets will 
be introduced as soon as animals are available. Since it is not 
known when or if any ferrets will be available, it is not known 
when an introduction will be made. 

15. The idea of a Memorandum of Understanding between the Department of 
State Lands and CMR concerning grazing has merit; we will pursue 
this matter as we start developing habitat management plans. 

16. The EIS does not propose to dramatically Increase deer and elk 
populations. The EIS does propose, however, the improvement and 
maintenance of habitat capable of supporting an overwintering 
population of 10 deer/sq.mi. and 2.5 overwintering elk/eq.mi. in 
suitable habitat (see page 5, wildlife objectives 7 and 9). 

17. The statement is somewhat misleading; see revised text page 43, 
paragraph 2. 

18. The revised livestock economics analysis now takes into account 
revenue derived from livestock earnings from the CMR. A detailed 
discussion of livestock economics is provided in Appendix 10. 

While a few ranchers with high dependency on the CMR will be ad- 
versely affected, the FWS does not gather specific information on 
the other factors you mentioned (indebtedness, etc.) to make a 
determination of who, if any, ranchers would be forced out of 
business. This determination depends on sociological as well as 
economic factors. The EIS does look at the effect of changes in 
livestock producer spending on the local economy. See Appendix 13 
for more discussion on this matter. 


256 


19. The EIS is proposing the improvement and maintenance of wildlife 
habitat capable of supporting an average of 10 deer and 2.5 elk/ 
sq. mi. on suitable habitat. Should depredation problems occur, 

CMR will coordinate and integrate, where feasible, management of 
CMR with objectives of federal and state agencies and private land- 
owners within and around CMR. 

20. The subject of predator control has been discussed in two previous 

EIS's: Operation of the National Wildlife Refuge System, and 

Mammalian Predator Damage Management for Livestock Protection in 
the Western U.S. You are correct that range condition has improved, 
but range condition and wildlife habitat are not synonomous. 

21. The FWS will coordinate CMR management when and wherever possible. 
Also, all private or third party rights associated with inholdings 
on CMR, will be honored when detailed management decisions are 
undertaken for individual allotments. 


COMMITTEE ON FINANCE 
Cwaixmah, Suecosftidrrm an TUX 
Rivimjb Ooivicx 

'SCmiteb -JMaies ,2>cnaic 

CMUKMAM, SUKOUMrmX CM 

WASHINGTON, D.C. 20510 Umttattow oh Comtmcto 

'-KD DtLtMTIO AUITO1ITT 

December 1, 1980 relict committee on 

eMALL MINUS 


Mr. Erwin W. Steucke 
Area Manager 

Fish and Wildlife Service 
Federal Building, Room 3085 
316 N. 26th Street 
Billings, MT 59101 

Dear Wally: 

Please find enclosed my statement on the Draft Environmental 
Impact Statement for the management of the Charles M. Russell 
National Wildlife Refuge. 

As you will note, I am generally pleased with the comprehensive 
nature of this DEIS. However, I do feel that further attention 
is needed to the question of livestock grazing on the Wildlife 
Refuge. 

I would appreciate being informed of all further action on 
the DEIS resulting from public comment. 

Thank you for your attention to this matter. 

With best personal regards, I am 


Sincerely 



Enclosure 


cc: Honorable Cecil D. Andrus 


Bnj-INOO Bum Shut Faux Hejhi Munu 

(408) 637-0780 (400) 782-8700 (408) 701-1874 (400) 448-4480 (400) 728-204J 

RECYCLED PAPER 


#4 AX BAUCUS 



1 -000-411-810* 


STATEMENT BY SENATOR MAX BAUCUS 
ON THE 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 
FOR THE 

MANAGEMENT OF THE CHARLES M. RUSSELL NATIONAL WILDLIFE REFUGE 

The Charles M. Russell Wildlife Refuge (CMR) represents one of 
the most valuable federal land holdings in the Western United States. 
Stretching from the Fred Robinson Bridge in the west down the Missouri 
River to the Fort Peck Dam in the east, the CMR is imposing. 

The scenery and wildlife are diverse. Elk, pronghorn antelope 
and mule deer roam the bottom lands, river breaks and sagebrush 
grasslands. Historically, use of the Refuge has been as varied as the 
topography. Grazing and commercial farming exist together with boating, 
hunting, fishing and touring. 

Under the unified management authority granted the U.S. Fish 
and Wildlife Service by P.L. 94-223, the goals for the CMR which have 
evolved from this diversity should continue to be recognized. The 
management philosophy must recognize the important interplay between 
the Refuge, its private, state, and federal neighbors and those with 
permits to graze their cattle on the Refuge. 

The U.S. Fish and Wildlife Service is to be commended for trying 
to meet its sundry management objectives for the CMR in the Draft 
Environmental Impact Statement (DEIS) for the management of the Wildlife 
Refuge which was released earlier this year. The analysis of the current 
status of the Refuge and the resulting management proposal are significant 
in the 44 year history of the CMR. 

I have just completed my review of the Draft Environmental Impact 
Statement. My review was supplemented with public comments on the DEIS 
shared with me by the many Montanans concerned for the future management 
of the CMR. My primary concern upon completing my study of this Draft 


Environmental Impact Statement is for treatment giyen domestic livestock 
grazing. For decades, the propriety of grazing on the CMR has been 
consistently recognized. Because of the integral role that agriculture 
plays in the economy of the region surrounding the Wildlife Refuge, the 
issue of grazing deserves close scrutiny. Thus, before a final 
management plan is adopted, I am urging the Fish and Wildlife Service to 
examine further any alternatives for improving wildlife habitat other 
than the suggested 33 percent cut in animal unit months CAUM) on grazing 
allotments. 

The DEIS recognizes that the Refuge is predominantly in good 
condition in terms of range vegetation. Only a small percentage (7%) 
of the CMR is in just fair condition as a result of livestock grazing. 

The portion of the Range in poor condition is due to prairie dog towns 
or natural flood plains. Thus, under these circumstances, the utilization 
of other wildlife habitat improvement techniques should be emphasized 
before turning to reductions in livestock grazing. 

With the continued economic viability of area ranches at stake, 
the onus is on the Fish and Wildlife Service to exhaust all possible 
methods of improving range conditions before suggesting the foreclosure 
of livestock grazing. 

As part of this more intensive study, the importance of on-the- 
ground consultations with ranchers and other land managers must be stressed. 
While the Fish and Wildlife Service has conducted public hearings and on- 
site inspections on the CMR, the magnitude of the decision being made 
warrants further consideration of the management alternatives as they 
affect agriculture. Those individuals whose livelihoods are directly 
affected by this management plan may well be able to suggest innovative 
rangeland and wildlife habitat enhancement methods. 


46 ? 


Specifically, the economic impact of this proposed management 
system deserves greater attention. While the DEIS notes that, on a 
regional basis, the loss of income is insignificant, common sense 
argues that the loss of 20,000 AUM's will have real and disastrous 
consequences for those stockgrowers who are primarily affected. Such an 
abrupt departure from longstanding management practices must not be 
entered into lightly. 

The additional study I am requesting does not deny the primary 
focus of the CMR as a wildlife refuge. By virtue of the designation 
of the area as a refuge, the mission of the Fish and Wildlife Service 
to protect wildlife habitat is apparent. However, my contention is 
that livestock grazing is a compatible use for the Refuge. Special 
protection for riparian regions, soil ripping, controlled burns, 
cooperative management efforts with area ranchers, and other novel 
management practices can, in my mind, result in the continuation of 
grazing at near present levels without serious damage to wildlife 
habitat . 

For their part, area ranchers have long recognized that the 
protection of the range quality and habitat of the CMR is critical for 
the long-term success of their operations. Through more intensive 
consultations, the Fish and Wildlife Service can underscore the necessity 
for sound and cooperative management practices to ensure the retention 
of individual allotments on the CMR. 

In summary, I recommend the following modifications be made in 
the management plan for the Charles M. Russell Wildlife Refuge: 


1 


- 4 - 

1. Alternative methods for the enhancement of Wildlife habitat 
and rangelands should be explored more fully rather than relying upon 
cutbacks in AUM's. 

2. Increased consultation and cooperation with adjacent property 
owners and area residents should be emphasized in formulating a management 
plan for the CMR. 

3. The management plan should provide flexibility in implementing 
any management plan to avoid sudden economic dislocation for grazing 
permitees . 


I* 

f* 


4. The DEIS should be supplemented to more specifically identify 
the economic impacts of livestock grazing cuts on the surrounding region. 


I* 


In conclusion, I am convinced that habitat for wildlife can be 
significantly enhanced without the unfortunate consequences for the 
area that would result from grazing cutbacks amounting to 33 percent. 

I stand ready to lend whatever legislative assistance may be necessary 
to accomplish this end. 




vtkI MELCHEB 




'>llCntie2> -&laiez utU 

j 

Response to U.S. Senator Baucus 


September 29, 1980 


1. The economic Impact has been reevaluated and the EIS revised (see 
text and Appendices) to more accurately reflect the economic situa- 
tion under various alternatives. 

2. In the pre-EIS studies, it was determined that current grazing was 
a primary limiting factor on the enhancement of wildlife habitats 
on CMR; hence, the alternatives were developed around grazing 
modifications . 


The Honorable Cecil D. Andrus 
Secretary of the Interior 
Interior Building 
Washington, D. C. 20240 

Dear Mr. Secretary: 


3. Public involvement has been, and will continue to be, emphasized 

regarding the planning and management of CMR. 


We have just completed a review of your Draft Environ- 
mental Impact Statement (DEIS) on Management of the 
Charles M. Russell National Wildlife Refuge. 


4. A phase-in period has been planned to reduce impacts of a sudden 
dislocation in grazing permittees. 

5. See response 1 above. 


The proposals and direction portrayed in the document give 
us a great deal of concern. While we recognize the reason for 
preparation of the document by the Fish and Wildlife Service, 
we believe the alternatives presented fall far short of 
addressing the issues in need of resolution. 




We are in total disagreement with treatment given domestic 
livestock grazing in the draft alternatives. The Executive 
Order establishing the Fort Peck Game Range in 1936 clearly 
recognized domestic livestock grazing as a compatible use on 
the Game Range. While subsequent legislation placed CMR 
management completely under the Fish and Wildlife Service, it 
did not direct that grazing use by domestic livestock be 
diminished or eliminated or that there were unresolvable 
conflicts between wildlife and domestic livestock use. The 
material presented in the DEIS does not present conflicts 
that cannot be resolved with some minor changes in direction 
regarding range improvements and some changes in the rather 
arbitrary goals and objectives outlined on pages 4 and 5 of 
the document. 

• 



Overall range condition in the Refuge is in exceedingly 
good condition and, with some minor exceptions, there appears 
to be little conflict between domestic livestock and those 
classes of wildlife where direct competition for the grazing 
resource would be expected. 




Another shortcoming in the document that we find exceed- 
ingly disturbing is the socio-economic treatment given to the 
grazing reduction impact. The document states that the regional 
economic effect due to grazing reductions would be insignificant 
under any of the alternatives. However, in the section 
assessing the consequences of the proposed action the authors 

• 



1123 Dirksen Building Washington. D.C. 20510 (202)224-2644 


The Honorable Cecil D. Andrus 
September 29, 1980 
Page 2 


clearly state that, due to a lack of information, a greater 
number of grazing operators could suffer adverse impacts than 
anticipated in the analysis. 


m 


While we recognize the primary purpose of the Refuge is 
to benefit wildlife, we recommend the Fish and Wildlife Ser- 
vice supplement the Draft Environmental Impact Statement. The 
supplement should recognize domestic livestock grazing as a 
legitimate use of the Refuge instead of treating it as a 
threat. Evidence does not bear out that past or current 
domestic livestock grazing is causing serious damage to the 
wildlife habitat, but evidence does bear out the negative 
economic impact of the proposed action. 

The supplement should provide changes in the goals and 
objectives to give recognition to domestic livestock grazing 
and do away with the self-imposed limitation on range improve- 
ments for domestic livestock. 


A nqw alternative should be developed which provides for N 
range improvements and improved grazing systems, along with 
some season of use modifications that would provide enhancement |<fi 
of the overall wildlife habitat without the detrimental effect r 
on the domestic livestock grazing program portrayed in the 
presented Draft Environmental Impact Statement. H 



Response to U.S. Senator Melcher and Congressman Marlenee 


1. The goals and objectives were formulated in accordance with FWS 
policies, regulations, legislative requirements, and public input. 
Domestic livestock are substantially recognized by first being a 
positive factor in manipulating wildlife habitat, and secondly, 
receiving all forage excess to the needs of wildlife. 

2. The regional economic effects are insignificant because the relative 
change on the six county area is a very small percentage change. 

Thus to the region, there would be no perceptible change in key 
economic variables such as employment or income as a result of 
these alternatives. The absolute effect to a few individuals, as 
measured without reference to the size of the six county area, may 
be large. While this change is important to these individuals, it 
does not seriously affect the human environment of the study area 
because the absolute changes have a small relative effect. 

3. The EPA has rated this document LO-1 (Lack of Objection - suffi- 
cient information); therefore, the FWS believes the draft document 
is adequate. Our governing legislation requires that wildlife and 
wildlife habitat receive primary benefit and that any other acti- 
vity must be compatible with wildlife. 

4. The FWS believes that Alternative D (Multiple Use) proposes to use 
livestock grazing in the manner you suggested. However, this 
alternative will not achieve wildlife objectives. 



SENATOR MARK ETCHART 

GLASGOW, MONTANA 59230 

HELENA AOORESS: 





stat ie*. senate: 


Box 229 

Glasgow, Mt. 59230 
October 30, 1980 


COMMITTEES: 

HIGHWAYS AND TRANSPORTATION 
NATURAL RESOURCES 


TESTIMONY GIVEN AT US. F&W HEARING GLASGOW, MT. OCTOBER 30, 1980 
ON DRAFT ENVIRONMENTAL STATEMENT ON MANAGEMENT 


OF CHARLES M. RUSSELL NATIONAL WILDLIFE REFUGE. 


My name is Mark Etchart. My interest in the management 
of the CMR is as an elected official representing Senate District 2 
and as a rancher who runs livestock on the Game Range. 

Since the hearings handout instruct us that "witnesses 
must direct their testimony to the contents of the document 
and to specific aspects of the proposed CMR management proposal 
or alternatives to the proposal" a citizen testifying at this hc* 
is given the choice of 5 bad options and is being asked which 
one he likes the least. Those of us who have participated <Jin 
every chance we could get to provide input to this draft EIS 
have the feeling our opinions have been given very little con- 
sideration thus far. 


Of the proposed alternatives the only one which would be aCCc >' G 
the "No Action Alternative" because it is the only one v/hich 
would not do considerable damage to the local economy. It 
specifies that livestock numbers would not change and I think 
that this provision chould be incorporated in whatever final 
action is taken. We have developed a system of management on 
the CMR whereby valuable livestock forage is utilized to produce 
a produ ct which provides our people with a high quality nutritious 
food from a renewable resource which would othv/rwise be largely 
wasted. This production is badly needed at this time to help 
our balance of trade by holding down meat imports which are 
a drain on our economy at a time when we are beinghurt badly 
by other necessary imports such as crude oil, and strategic 
minerals vital to the maintance of our technological society. 


Also we have had good hunting and recreational opportunities 
on the CMR. We have found that if we control the coyote we 
can raise a tremen dous amount of game on the federal and private 
lands. Provide opportunities for boating, hiking, horseback 
riding, camping, fishing, and generally enjoying the outdoors 
WMifl still utilizing the forage production to raise livestock 


-Jp- ■ 




MOH 'IF A. M A ST AT IE SIEIVATIE 


SENATOR MARK ETCHART 
GLASGOW. MONTANA 59230 
HELENA AOORESS: 


v/hich generate n ew wealth which has a multiplier effect of 5 
to 1 as far as the rest of the economy is concerned. These 
livestock generate taxes to support our county government, and 
educate our school children. They provide jobs in town for 
local business. With our national economy in such a shambles 
we should deliberate long and hard before taking action which 
hurts our workers, our businesses and raises the price one of 
our basic food products. 

The proposed Action Alternative would penalize Etchart 
Ranch heavily by reducing our livestock grazing on the CMR 
by 47%. And mind you this is on range which was shown to be 
97 % good to excellent in condition by Fish and Wildlife range 
surveyors. If a tremendous cut like that actually is enforced 
we would only be allowed to graze about 17% of the available 
forage. This is wasteful, not necessary for game production 
and serves absolutely no useful purpose unless one considers 
stopping livestock grazing a useful purpose. 

The economic data preserted is misleading as to the real 
affect. Losses in livestock production are shrugged off as 
a small percentage figure of the total economy using bust year 
prices as the basis, and other benefits are balooned by using 
dollar amounts accumulated over several years. This draft 
EIS has to be the weakest document I have seen in a long time 
in the quality of the economic analysis that went into it. 

Northeast Montana is vitally interested in the future 
management of the CMR. We cannot let this valuable resource 
be taken over by the prairie dog and the coyote when we have 
people in the cities who already feel that they are paying much 
to mu di for food at the present time. Good judgement pint 
to the NO ACTION ALTERNATIVE as the only one which should be 
considered. 

Thank You 

C/c- A 6. t/- 
Mark Etchart 
State Senator District 2 


© 


COMMITTEES: 

HIGHWAYS AND TRANSPORTATION 
NATURAL RESOURCES 



Response to Montana State Senator Etchart 


1. The regional economic effects are Ins ignif leant because the relative 
change on the six county area is a very small percentage change. 

The absolute effect to a few individuals, as measured without 
reference to the six county area, may be large. See also the 
revised economic evaluation in the text and appendices. 






AMERICAN WILDERNESS ALLIANCE 

4260 East Evans Avenue • Suite 8 • Denver, Colorado 80222 
(303) 758-5018 


BOARD OF TRUSTEES 
Sally A Ranney 

Nancy J Borra 

Paul W. Richard 


BOARD OF ADVISORS 
Dr. John Craighead 
LW. (BiU) Lane. Jr. 
Francois Lcydct 



Dr. Roderick Nash 
Margaret Wentworth Owing* 
Eliot Porter 
James A. Posewitz 
Wallace Stegner 


Executive Director 

Clifton R. Merritt 



Mr. Wally Steucke, Area Manager 
U. S. Fish and Wildlife Service 
Federal Building, Roan 3035 
316 North 26th Street 
Billings, Montana 59101 

Dear Mr. Steucke: 

This is to coiment for the official record on the Fish and Wildlife 
Service's Master Plan for the Charles M. Russell National Wildlife 
Refuge. 

The American Wilderness Alliance is a Western-based national non-profit 
organisation dedicated to prenoting the conservation and wise use of 
the nation's dwindling wilderness, wildlife habitat and wild river 
resources. Many of our Montana members are familiar with the Charles 
M. Russell National Wildlife Refuge. As a native Montanan, I have 
visited the Refuge on numerous occasions throughout the past 30 years. 

We greatly appreciate efforts of the Fish and Wildlife Service, as ex- 
pressed in the Master Plan, to address and resolve some of the problems 
that have plagued the Wildlife Refuge for rany years and kept it from 
once again becoming the great wildlife mecca known in early pioneer days. 

Here are our more specific cements regarding the Plan: 

Grazing 

We strongly support the decision of the Fish and Wildlife Service sub- 
stantially to reduce domestic livestock grazing in the Wildlife Refuge. 
Livestock grazing has continued through the years to dominate use of 
the Refuge, despite the fact that the original order establishing the 
area provides that wildlife shall receive primary consideration. From 
our own repeated observations and knowledge, severe overgrazing by live- 
stock has continued to depress the numbers and quality of wildlife on 
the Refuge, especially such species as elk, bighorn sheep and grouse 
which depend heavily on a grassland habitat throughout their live cycles. 

We urge that the Fish and Wildlife Service go further, however, and 
adopt an alternative to use livestock grazing as a management tool to 
be administered selectively on a prescription basis in order to obtain 
the best possible wildlife habitat conditions. 


Mr. Wally Steucke 


4, 1980 


Also, we find very little in the Plan to indicate how the Fish and Wildlife Ser- 
vice concluded, on average, that livestock grazing should be reduced by one-third. 
More specific information on this subject should be provided. Perhaps such in- 
formation would support a 40 per cent ac 50 per cent reduction. Who can tell from 
the lack of data presented? 

Wildlife Reintroductions 

The Alliance wholeheartedly endorses that part of the Plan which provides far the 
re-introduction of bighorn sheep, black-footed ferrets, swift faxes and peregrine 
falcons to the Refuge. Moreover, conditions as nearly ideal as possible should be 
established and maintained on the Refuge far each species to assure its successful 
re-introduction and perpetuation. 


Farming 

We support, too, phasing out farming activities along the bottaulands of the 
Missouri River in the Refuge. This would benefit most wildlife and restore 
natural integrity to the wildlife setting. 


Manipulation of Habitat 

Hie American Wilderness Alliance is unalterably opposed to ripping (plowing) up to 
10,000 acres of the Refuge to irrprove vegetative productivity. This is an arti- 
ficial practice that is in contradiction with the purpose far which the Refuge was 
established — to protect and enhance wildlife populations in a natural setting. As 
Aldo Leopold wrote in the 1930's, when you remove the wild, natural habitat from 
wildlife, you no longer have wildlife management. You have animal husbandry. Sub- 
stantial reduction in livestock grazing on the Refuge will increase and maintain 
much greater vegetative productivity in general far wildlife, without destruction 
of natural values. 


Predator Control 


Finally, we respectfully request that the Fish and Wildlife Service Master Plan 
contain clear direction that predator control shall occur only when absolutely 
necessary, for example, when it is essential to safeguard threatened or endangered 
species. There should be no routine elimination of predators to benefit livestock. 
If ranchers desire to graze livestock on the Refuge, they most be willing to 
accept the risk of predation. The consideration of all wildlife should cote first, 
as legally required. 


Thank ycu for the opportunity to comment on this important natter. 


Sinoerely, 



Executive Director 


CFM: lw 


oc: Senator Max Baucus 


Response to American Wilderness Alliance 


1. Grazing is to be used as a management tool under the Proposed 
Action. Each allotment will be evaluated and grazing prescribed to 
achieve desired habitat responses. The Intensive Wildlife Manage- 
ment alternative also specifically provides for prescription grazing 
to benefit wildlife. 

2. The amount of forage available to livestock was computed on a 
section-by-section basis. Since there are over 1,000 sections on 
CMR, a listing of the tabulation of each is beyond the scope of 
this document. The 32.6 percent reduction is an average of the 
reductions applied to these sections. See revised Appendix 15. 

This amount of reduction generally fulfilled the requirements for 
wildlife (see Appendix lb). 

3. Preventive predator control or wholesale control are prohibited on 
CMR. Control of the offending predator is, however, permitted on 
CMR upon documentation by Animal Damage Control personnel. 


299 



Response to Animal Protection Institute 


1. During the habitat evaluation phase of the planning process. It 

became apparent that many species had similar habitat requirements. 
Rather than selecting an animal with little literature available 
and not easily recognized by the public, game species were selected, 
among others. The habitat components necessary for these animals 
also fit the habitat components necessary for a large number of 
non-game wildlife also. 



— ' OF WILDLIFE December l, 1980 

Erwin U. Steucke, Area Manager 
U.S. Fish and Wildlife Service 
Federal Building, Room 3085 
316 N. 26th St. 

Billings, MT 59101 

RE: Draft- Environmental Impact Statement, Management of 

Charles M. Russell National Wildlife Refuge. 


Dear Wally, 

I have read the CMR Master Plan and wish to submit the following comments on 
behalf of Defenders of Wildlife, a national conservation organization with a 
longstanding interest in the National Wildlife Refuge System and its proper 
administration . 

Our organization appreciates the opportunity to have been closely involved 
in the planning process that preceded the issuance of this document. I have 
personally toured the refuge on several occasions, and seen many of the problems 
first-hand. Fish and Wildlife Service personnel have made themselves readily 
available to answer all questions and requests, and have done as much as possible to 
encourage public participation. From a public Involvement standpoint, the FWS 
has done a first class job, and that's very Important. 

The CMR is one of the most prestigious units of the National Wildlife Refuge 
System} it's not only the second largest refuge in the continental U.S., but also 
contains a diversity of habitats and wildlife. Because of its high visibility, 
the management direction for the CMR will tend to set policy for other refuges 
across the country. Therefore, management on the CMR must always be considered 
in a national context, and decisions should be made with the best interests of all 
U.S. citizens in mind, in accord with established laws, regulations and policies for 
the national wildlife refuge system. 

Since grazing is probably the key issue of the CMR Master Plan, I would like to 
reiterate FWSpoilcy on secondary economic uses of the refuges. This policy was 
made very clear in the 1979 "Final Recommendations on the Management of the National 
Wildlife Refuge System." Task Force Recommendation 14 stated, "Grazing, timber 
harvesting and agricultural practices may be abusive and should only be used when 
necessary for proper management of wildlife resources, keeping in mind the 
desirability of maintaining natural ecosystems." 

Assistant Secretary Herbst agreed with the recommendation, and further added: 
The Service's implementation should show on a reasonable basis that these management 
practices are employed for the benefit of and are not harmful to wildlife and 
wildlife habitat... Without exception, any economic uses of the NWRS must be 
demonstrably compatible with Service objectives to preserve, protect and enhance 
wildlife habitat." 


1244 NINETEENTH STREET, NW • WASHINGTON, DC 20036 • (2021 659-9510 


Mr. Wally Steucke- -page two 

This stated policy makes two very important points. First of all, grazing 
should either be beneficial or neutral to wildlife and wildlife habitat before 
it can be authorized. Secondly, the FWS must be able to demonstrate that it's 
beneficial or neutral. A national wildlife refuge should be one place where the 
wild animals needn't bear the burden of proof. 

It's in the context of these preliminary comments that Defenders of Wildlife 
will make its more specific comments on the CMR Master Plan. 

The DEIS presents a great deal of information which substantiates the chief 
complaint of conservation interests: livestock grazing has had, and is having, 

a substantial adverse impact on the CMR's wildlife. The DEIS clearly demonstrates 
that livestock grazing is presently preventing the refuge from fulfilling the objectives 
for which it was established. 

These statements begin on page ix and permeate the document. Page lx, paragraph 
2 reads, "Wildlife habitat on the refuge is only in fair condition. Present deficiencies 
in habitat include lack of residual cover (grasses and forbs) on upland sites, around 
ponds and in hardwood draws, poor quality and small quantity of deciduous shrubs and 
trees in hardwood draws and along minor stream courses, poor quality sagebrush stands 
and insufficient timber density in some areas." On page 16, it's noted that 
riparian zones, undoubtably the most productive wildife zones in arid regions, are 
c ® ns ^ ere< ^ sacrifice areas' on the CMR because of cattle concentrations. On page 
26, paragraph five, the FWS readily acknowledges that the present situation does 
not provide a wildlife refuge situation, that livestock grazing is equal to or above 
wildlife for resource allocations. On page 63 , we get some of the specific impacts 
livestock grazing has had on individual species. Cattle in the Two Calf area are 
depressing bighorn populations; grazing is holding sharptail grouse production far 
below what it could be; grazing around ponds and other waterfowl areas has kept 
waterfowl production far below what it could be ; mule deer and antelope suffer from 
insufficient forbs; livestock grazing and trampling of browse species has caused 
a downward trend for deer and grouse. On page 65 , the FWS illuminates another 
glaring problem: forage on the most favorable locations on the refuge have always been 

allocated almost solely to livestock, while the extremely rugged and dry areas have 
been given to wildlife. 

In sum, the DEIS makes a strong case for reducing livestock numbers on the CMR. 

Given these findings, one would then logically expect to find a reasonable range of 
alternatives detailing how these livestock reductions might take place. This is 
where the DEIS falls short; instead of providing several workable 1 alternatives, the 
FWS provides only one viable option. The others only tend to distract the reader's 
attention. 

Alternative A, the No Action Alternative, calls for keeping things the way they 
are. Given the F^S admission that the current situation does not reflect a national 
refuge situation, that alternative would apjiear not only undesirable, but 
illegal as well. Further, given the public's dissatisfaction with past wildlife 
management, it obviously isn't a viable option. When Congress gave the FVS sole 
management authority for the CMR in 19?6, it did so with the understanding the CMR 
would finally be managed as a wildlife refuge. This mandate is clearly defined in 
the legislative history of P.L. 94-223. 

Alternative C, the Intensive Wildlife Management alternative, would require 
not only new legislation, but large budget increases that are highly unlikely. 



24 ? 



Jy OF WILDLIFE 


Mr. Wally Steucke — page three 


Further, this alternative calls for such a level of manipulation and management 
that it would go directly against the CMR's mission statement, which calls for 
the area to be managed and preserved in a "generally natural setting." 


This alternative was highly disappoint^, as it should have been tho one where 
the FWS could have formulated the ideal management direction for wildlife, and then 
allowed public comments to take over. The one part of this alternative that does 
deserve consideration is the part that deails with grazing. Under this alternative, 
grazing would be used as a tool to achieve or maintain desired wildlife habitat. 

This approach makes much better sense for a wildlife refuge than' a system that 
permits routine grazing without consideration of overall grazing Impacts. 


Alternative D, the Multiple Use alternative, has no logical place in this 
DEIS, as it's clearly improper for a national wildlife refuge. By inserting such 
an alternative many people are led to believe that it's really a live option. 

Alternative E, the No Grazing alternative, would be very difficult to administer 
because of the numerous state and private inholdings. While this alternative obviously 
would be very beneficial to many species of wildlife, it could serve to reduce other 
populations. To the extent it can be demonstrated that livestock grazing is beneficial 
to particular serai species, it should take place. 

That leaves us only with Alternative B, the alternative proposed by the FWS. 
Alternative B is a reasonable alternative, but only one of many management alternatives. 
By making the other alternatives so unattractive, the FWS leaves the public with 
little choice. It's like throwing darts at a board, and then drawing rings around 
where they hit. It makes it appear that the FWS has already determined what action 
it wants to take, and is now going through the motions of receiving public comment. 


The FWS Proposed Alternative isn't without problems. First of all, not enough 
information is presented for citizens to make informed decisions about what the 
best level of grazing might be. I've followed the FWS process closely, and I'm 
not able to deduce the precise methodology which the FWS has used to determine 
appropriate grazing levels. It follows, then, that I'm unable to tell whether the 
proposed reductions are enough, or too much. 

The preferred alternative seems to be predicated on a "light grazing" scenario 
that was established by a single scientific paper and then reinforced by cronies at 
the National Bison Range. This doesn't seem like the level of rigorous scientific 
documentation that the central thesis of any plan should have. 


What the preferred alternative does, to the best of my understanding, is to take 
reductions based on steepness of slopes and distance from water. This is based on the 
assumption that cattle can't use these areas. What the preferred alternative serves 
to do, then, is to concentrate the cattle on the flat areas near water — certainly 
prime areas for wildlife as well as livestock. On page vlii, the DEIS states 
that riparian zones provide one of the most important and productive wildife 
habitat types. It further states that this type of habitat is in short supply on the 
CMR. To the extent that the proposed action fails to acknowledge the riparian 
zone conflicts, one can expect that habitat to remain sub- par. 


The DEIS does not make it clear that much of the refuge cannot be used by 
cattle because of ruggedness and distance from water. This is why so much of the 
range is in good to excellent condition. The conflict between wildlife and livestock 
probably exists on only about 1C$ of the refuge, but these are the core areas for 
wildlife production. 


* 'Defenders 

OF WILDLIFE 


Mr. Wally Steucke — page four 


This problem gets to the core of the deficiencies of not only the proposed 
alternative, but of the entire DEIS: the analyses of the various alternatives are 

too generalized and non-specific. The CMR is an extremely large and diverse 
refuge, but the DEIS would lead us to believe the refuge is rather homogenous. 
Particularly, the proposed action fails to address the critical problem of how 
to resolve livestock-wildlife conflicts on the prime areas, such as the riparian 
zones and other flat places near water. The proposed action calls for routine 
grazing, on a year- in and year-out basis, without clearly demonstrating that such 
grazing will be beneficial or neutral to wildlife. 

A prescription grazing system, such as proposed in the Intensive Wildlife 
Alternative, would be a more logical and far more predictable means of reaching 
the stated wildlife goals for the CMR. The option of retiring allotments in 
order to form severed no-grazing areas, and then rotate these areas also has some 
appeal. If the rest periods were of sufficient length, this might be the way to 
best avoid making riparian zones "sacrifice areas." 

In sum, while the Preferred Alternative seems to be a step in the right direction, 
Defenders of Wildlife strongly feels that the philosophy and methodology underlying 
the alternative are not consistent with a wildlife refuge situation. Basically, the 
preferred alternative allows routine grazing to continue, and glosses over the 
obvious conflicts in the prime areas near water. Only through a prescription 
system or a rotation system with long rest periods could such conflicts be eliminated. 

There are many other specific parts of the DEIS that deserve comment. Since no 
particular alternative in the statement concurs with our views, I'll comment 
specifically on certain issues. 


Endangered Species Rolntroductlon 

Since one of the primary mission of the refuge system is the recovery of 
threatened and endangered species, it's only logical that re introduction of species 
like the peregrine, swift fox, black-footed ferret and bighorn sheep should be 
considered. We strongly support these re introductions. We further feel that an 
objective review should be undertaken of the feasibility of reintroducing bison. 

If bison are feasible on the National Bison Range, certainly it's possible on 

the CMR. The pros and cons need to be weighed, and the public should be involved in 

the question of whether we Want, need or can afford bison on the CMR. 




Farming 

We strongly support the phase-out of farming along the Missouri River bottoms. 
These operations not only detract from the otherwise natural setting of the river, 
but also fail to pass the test of being neutral or beneficial to wildlife. While 
these operations may benefit non-native species like turkeys and pheasants, they 
take away highly important food and cover from other native species. Ungulates 
in particular need thick, riverbottom habitat to afford relief from harsh winter 
conditions. 

Fire Management 

We support the fire management in the proposed alternative, that would allow 
prescription burning as well as some natural bums. Fires have always been an 
integral part of the prairie ecosystem, and are largely responsible for the 
diversity of habitats found on the refuge. 


Mr. Wally Steucke — page five 

Predator Control 

Even though this issue has caused considerable controversy in the past, the | 

DEIS essentially sidesteps it and falls to give predator control the indepth 
discussion it deserves. The public feels very strongly about killing wildlife 
on a national wildlife refuge in order to protect livestock. A6 it stands, the 
proposed action regarding predator control in the DEIS directly contradicts 
stated FWS policy. In "The Final Recommendations on the Management of the National 
Wildlife Refuge System," Assistant Secretary Herbst states, "Animal control will 
be undertaken only to assure balanced populations consistent with proper management 
of refuge habitat. In no instance should control programs be based solely on a 
need to alleviate damage to economic users, such as farmers or grazers. " (my emphasis) 
The proposed action obviously needs to be brought into conformity with FWS policy. 



Soil Ripping 

The proposed alternative calls for the ripping of as much as 10,000 acres of 
prairie in order to improve vegetative diversity. We oppose this proposal for at 
least two reasons. First of all, it disregards the mission statement of the refuge, 
which calls for generally natural management. This type of manipulation is 
aesthetically displeasing. Secondly, this pan spots which the FWS proposes to 
plow up may have value of their own. While they may not be important from 
a vegetative standpoint, they may be Important strutting grounds for grouse, 
or they may be good mousing areas for raptors or other predators. Simply stated, 
we may not appreciate what good they are. Besides, more is not necessarily better; 
we need diversity, even if we don't understand it. 




Cabin sites 

The Proposed Alternative calls for retention of cabin sites on the refuge. 
From refuge policy standpoint, recreational homesites seem highly inappropriate, 
and probably illegal. In some instances they may conflict directly with wildlife. 
The FWS should be phasing out the cabins, as the Forest Service is doing on our 
National Forests. 


Range improvements 

We agree with the FWS statement on page 9* "Water developments, fencing, farming, 
etc., are generally inconsistent with wildlife goals and will only be used when 
wildlife objectives cannot be achieved through other measures." Generally, range 
improvements have done far more to hurt wildlife than they have to help it. We 
also strongly agree that FWS funds should not be spent on livestock where wildlife 
benefits can't be identified. Livestock management has eaten up too much of the 
refuge's budget in the past. 


Environmental Education 

Although this is one of the primary missions of the refuge system, the DEIS 
pays environmental education scant attention. A major problem with the CMR is that 
many people don't understand what a treasure it is. They don't know about its 
rich history or its incredible wildlife diversity. The refuge needs much more than 
a token tour route. It needs some tasteful, lnobtrusive displays and a heavy dose 
of publicity. The CMR needs to come out of hiding. 


Road Management 

This is another controversial issue that received little attention in the 
DEIS. Vehicle traffic needs to be restricted to the minimal amount needed 

for people to visit the refuge, without unduly affecting the wildlife resource. 

This is an extremely important part of refuge management, and the FWS should 
consider a separate travel plan of the CMR which would be available for public review. 




‘Defenders 

OF WILDLIFE 


Mr. Wally Steucke — page six 


b 


Corps- FWS Jurisdictional Problems 

This question has serious overtones to overall CMR management, yet it receives 
only scant attention. We feel that the FWS should aggressively seek to resolve 
jurisdictional disputes with the Corps of Engineers before this problem erupts 
again, and threatens the refuge. 

Thank you in advance for the consideration of these views j while some of our 
complaints are fundamental in nature, many of the comments are specific and we’re 
hopeful that the FWS will make appropriate changes in the FEIS. If you or your 
staff has any questions about these comments, please contact me. 


Sincerely, 

/ i)s>JL — 

Max Baucus Hank Fischer 

John Melcher Montana representative 

Ron Marlenee 30^ East Franklin 

Missoula, MT 59801 


292 


Response to Defenders of Wildlife 

1 . 

The FWS considered five alternatives including two not within its 
augmentation authority (as per CEQ regulations) . Three of the five 
alternatives detail how livestock reductions might take place. 

2. 

The text of Alternative C, Intensive Wildlife Management, in view 
of public comment and further evaluation, has been rewritten to 
reduce some of the more costly elements (fencing and land acquisi- 
tion) while retaining the intended purpose expressed in the name of 
this alternative. 

3. 

The amount of forage available to livestock was computed on a 
section-by-section basis. Since there are over 1,000 sections on 
CMR, a listing of the tabulation of each is beyond the scope of 
this document. The 32.6 percent reduction is an average of the 
reductions applied to the sections. See also revised Appendices lb 
(new), 2, and 15 for methodology. 

4. 

CMR habitat was evaluated on a section-by-section basis and actions 
prescribed for each. See response #2 above. 

5. 

FWS experience has shown that bison management by a government 
agency is both difficult and expensive. Therefore, use of bison to 
manipulate vegetation for wildlife was not selected for the Pro- 
posed Action. The FWS will work with any permittee who proposes to 
substitute bison AUMs for cattle AUMs in a CMR allotment. Bison 
reintroduction is included in the Intensive Wildlife Management 
alternative. 

6. 

Predator control has been fully addressed in the FEIS-Mammalian 
Predator Damage Management for Livestock Production in the Western 
U.S., and also in the FEIS-Operation of the National Wildlife 
Refuge System. 

7. 

After reviewing public comment and reexamining pertinent research, 
the FWS has concluded that soil ripping is not a viable manipula- 
tive technique for habitat management on CMR. All references to 
ripping have been deleted from the Proposed Action. 

8. 

The cabins are under the authority and are leased from the Corps of 
Engineers on designated areas. 

9. 

Plans in the Proposed Action provide for as much development and 
activity in wildlife interpretation and education as our projec- 
tions indicate there will be demand for in the foreseeable future. 


10. Road access and travel has been addressed in the planning and EIS. 

A copy of the access map is available from the refuge headquarters 
in Lewistown. 

11. FWS and COE are working together under a Memorandum of Agreement 
and will continue to work together to resolve all future conflicts. 


S3 


ECOLOGY CENTER OF SOUTHERN CALIFORNIA 

Project of Educotionol Communications. Inc 
P O. Box 35473. Los Angeles. CA 90035 


Telephone: (213) 559-9160 


October 12, 1980 


Mr. Erwin Steucke 
Area Manager 

U.S. Fish and Wildlife Service 
Federal Building 
Room 3035 

316 North 26th Street 
Billings, MT 59101 


Dear Mr. Steucke, 

The members of the Ecology Center of Southern California are concerned that 
the one-million acre Charles M. Russell National Wildlife Refuge management 
plan will not adequately protect the wildlife species in this habitat. 


While the preferred alternative is a step in the right direction it seems to 
call for too much artifical habitat manipulation. We are glad that grazing 
has been cut by 33% but overgrazing Will still occur and thus reduce the necessary 
forage and cover for the deer, elk, antelope, bighorn sheep and other species 
in the area. Our wildlife refuges is not the place to allow grazing if it 
hinders the protection of the flora and fauna. 

We look forward to hearing of your revision of the Environmental Impact Statement 
on this matter. 



Novemben 1 5, / 9&0 

fnvin H. Steucke, Anea Managen 
Flak and. Hildlife Sen. vice. 

Fedenxil Building. Room 3035 
3/6 No nth. 26th. ftneet 
Billings, Montana 5910 / 

Dean Sin: 

The punpose of. thin ietten in to fonmally voice the. opposition of the 
Fond Reck (ah in Association to Aitennative ( in the Unapt Environmental 
Impact Statement. 

Thene is no one that has a gn eaten love fon animals than uouns tnuly but 
thene one a tot of "human animals" in this anea that neatly, havenjt 'much to 
look fonwcuid to in the summen but to get back out to the cabin (if they 
one not alneady living, thene yean nound as some «•) as that is neatly 
all the activity thene is anound this anea. He one a small town and do not 
have all the activities that one offened in the lanyen cities. 


be fane any senious thought is given to dispose of the cabin anea, someone 
had beiten come up with an aitennative plan fon the local citizens to have 
if they can't have thein cabins. 


Respectfully youns, 

FOR Tit FORT RtfK (MIN ASSOCIATION 


Hilma Bosh. Secnetanu 
Box 25 / * 

Qlasgow, Montana 59230 


203 


Response to the Fort Peck Cabin Association 


1. Under the Proposed Action, the cabins will remain. For action under 
the Intensive Wildlife Management Alternatives, see revised text 
page 81. 


GARFIELD COUNTY COMMERCIAL CLUB 


JORDAN, MONTANA 59337 

November 12, 1980 


Erwin W. Steucke, Area Manager 
Fish & Wildlife Service 
Federal Bldg. , Room 3035 
316 North 26th Street 
Billings, Montana 59101 

Re: Draft Environmental Impact Statement on the Management of 

Charles M. Russell National Wildlife Refuge 

Dear Sir: 


On behalf of the Garfield County Commercial Club, I am writing 
this letter to you to indicate our position on the Draft Environmental 
Impact Statement on the Management of the Charles M. Russell National 
Wildlife Refuge. The following are our thoughts coricerning the DEIS: 


1. Our biggest concern with the proposed action as set out in 
the DEIS is the possible severe economic effect it will have on Gar- 
field County. It is admitted in the DEIS on page 79 that the proposed 
action will have high adverse impacts on at least 6 livestock operators. 
Our conversations with the various land owners which would be effected 
by the proposed action indicate that almost every major land owner would 
be adversely affected. The 337» reduction in AUM's will undoubtedly 
not only drastically reduce most of the land owners income but will 
also have an adverse economic effect on the rest of the economy in 
Garfield County. With the severe economic conditions that have plagued 
the farmers and ranchers in the past two years, this type of a reduction 
could be catastrophic. This is especially true since most of the ranches 
are running on a high debt and have a very low profit margin. Obviously 
we realize that the main goal in the management of the CMR is to manage 
the wildlife and the game refuge. However it is our position that such 
a severe economic blow to the various ranchers should be justified by 
a clear need for the proposed action. From our analysis of the DEIS it 
does not appear to us that there is a clear need for the proposed action. 


« 


2. The main thrust of the DEIS seems to be to the effect that the 
condition of the wildlife habitat in the CMR is currently of only fair 
quality. The goal of the proposed action seems designed to increase 
the quality of the habitat from good to excellent by the year 2000. We 
would submit to you first of all that there is nothing in the DEIS which 
would indicate that the CMR is currently over-stocked with livestock and 
that this is what has caused the poor quality of the habitat. The biggest 
problem in the past with the CMR seems to have centered arount the fact 
that livestock grazed more intensively around the watering areas. The 
reduction of the AUM's is not going to decrease this problem in any way. 

We would submit that the best alternative would be to develop further 
water projects and also put in more cross fences. 

Jordan, Garfield County, Montana, Southern Gateway to the Charles M. Russel National Wildlife 
Range and HeU Creek State Park. The Center of Eastern Montana’s Agricultural and Livestock In- 
dustry and The Heart of The World’s Finest Deer and Antelope Hunting. Home of ancient Fossils. 


Erwin W. Steucke 
November 12, 1980 
Page 2 


Secondly we would contend that there is no justification in the 
DEIS for the increase in wildlife AUM's from the current level of 
50,000 to 69,000 AUM's in 1985 and 74,000 AUM's in the year 2000. 
There is nothing in the DEIS which indicates that the wildlife num- 
bers are currently inadequate. Further there is no reason given why 
wildlife numbers should be increased. Therefore we would ask that 
you justify to us why there needs to be 74,000 wildlife AUM's in the 
year 2000. 


3. We would also object to the proposed action alternative in 
terms that it does not meet the stated goals of the CMR as set out 
in pages 4, 5, and 6 of the DEIS. The basic goals of the CMR appear 
to be the management of the wildlife on the game refuge in a state 
similar to that which existed a hundred years ago. The DEIS seems 
to address itself mainly to the maintenance of certain species of 
wildlife as well as the increase in the numbers of certain types of 
wildlife. The basic theory of the proposed action alternative seems 
to be that the improvement in the grazing conditions from good to 
excellent will some how cause a big improvement in the quality and 
quantity of wildlife on the CMR. We would contend that this basic 
conclusion of the proposed action is erroneous for at least two rea- 
sons. The first is that there is no clear foundation given in the 
DEIS which would indicate that the current habitat conditions have 
discouraged the wildlife in any manner. Secondly it is fairly ap- 
parent from talking to land owners on the CMR that predators are 
the biggest problem in terms of keeping and maintaining wildlife. 

It seems incredible that the proposed action alternative fails to 
address itself to this problem at all. On page 65 under the con- 
sequences of the no action alternative, it is admitted that coyo- 
tes do have an effect on certain wildlife populations. It seems 
amazing to us that the managers of the CMR would rather cut the AUM's 
of the land owners and thereby cause them serious economic disadvan- 
tages rather than institute a program of killing predators. It is 
our contention that the DEIS is deficient in this respect and that 
at the very least further study should be given to the predator factor. 


4. Finally we would like to point out that the proposed action 
alternative will most definitely cause a serious adverse reaction 
from various land owners. In the DEIS there is some discussion con- 
cerning the fact that the introduction of certain types of wildlife 
including elk and the Rocky Mountain Bighorn Sheep was impeded be- 
cause of adverse land owners attitudes. It would appear to us that 
the managers of the CMR should be interested in what the land owners 
attitudes are going to be to the various management alternatives. If 
the managers of the CMR are interested in introducing certain species 
of wildlife and in maintaining those species, it would only seem logi- 
cal that they should try to get the assistance of the various land 


& 


Erwin W. Steucke 
November 12, 1980 
Page 3 


owners. It is our contention that this proposed action alternative 
would be a step in the opposite direction and that it will most likely 
jeopardize the introduction of any new species of wildlife. 

Overall it is our conclusion that the proposed action does not 
meet the goals of the CMR and would have serious adverse effects not 
only upon the economy of Garfield County but also upon the future 
management of the CMR. Therefore we would respectfully submit that 
the no action alternative would be the best alternative at this time. 

We would also suggest that certain changes could be made in the manage- 
ment of the CMR including the development of further water projects, 
the building of more fences and a much more intensive effort to con- 
trol the predators. These types of changes would have a much better 
overall effect on the management of the CMR and would have more ad- 
vantages to everyone concerned. 


Sincerely, 

Ylia/s iXct l fit 


Nick Murnion, Secretary/ 
Garfield County Commercial Club 


iry / 


NCM/crm 


cc : John Melcher 

Max Baucus 
Ron Marlenee 
Pat Williams 

Sec. of Dept, of Interior 


2*4 


Response to the Garfield County Commercial Club 



1. The impacts to the ranchers in Garfield County, are on an average not 

severe. Generally, changes in income and sale are in the range of 
3 to 7 percent. It is true that all ranchers will be affected, but 


Jordan, Montana 59337 

the changes to the ranchers of Garfield County are not substantial. 
Only the few high dependency ranchers would be seriously affected. 


December 1, 1980 

2. In examination of HEP values compiled on allotments on the refuge, 



it has been concluded that additional water development would be 
detrimental to most wildlife species in that it would distribute 


Mr. Erwin W. Steucke, Manager, 

livestock into areas now used almost exclusively by wildlife and 


Fish & Wildlife Service 

that are needed by wildlife. 


Federal Building, Room 3085 
316 North 26th Street, 

3. Evaluation of wildlife habitat in the initial portions of the EIS 


Billings, Montana 59101 

process showed some serious shortcomings in the quality of wildlife 
habitat (see Appendix 2). The 6hift in wildlife AUMs will improve 


Dear Sir: 

this habitat. CMR is a wildlife refuge, and wildlife receive 
highest priority. This is stated in the Executive Order establish- 
ing CMR, and in the Refuge Administration Act. Page 5 gives the 


After reviewing the draft of the Environmental Impact State- 

wildlife objectives. 


meat on the Charles M. Russell National Wildlife Refuge, the 
Garfield County Commissioners believe the adoption of the 

4. The FWS acknowledges that predators may influence other wildlife 


no action alternative would be in the best interest of the 

populations; however, the FWS also recognizes that predators are 
wildlife and important in natural management. High quality habitat 


county and its residents. Thank you. 

will support more wildlife than mediocre habitat even with relatively 
high predator populations. 





Arthur W. Larson, Chairman 

5. The Proposed Action will, in the judgement of FWS, allow the refuge 



to meet its objectives and provide stability to permittees. The 


FWS will continue to coordinate and integrate its management objec- 
tives whenever feasible with those of its neighbors. 


Kenneth A. Coulter, Member 


Carl M. Hallberg, Member^ 



Garfield County Commissioners. 



oh. Jt > 7&C 

7 1* 



p.Q 7 


Garfield - McCone Legislative Association 

BRUSETT, MT 59318 


Phone 406-557-6182 


To be entered as written testimony. 
Referrence — EIS-CMR Nat. Wildlife Refuge. 


Erwin W. Steuke, Area Manager 
Pish & Wildlife Service 
Federal Building, Room 3085 
316 N. 26th Street 
Billings, HT 59101 

After thouxghly reviewing the entire ETS statement we are in complete disagreement with 
all of the four alternatives. No. (1) would be disasterous to the entire area, including 
the surrounding public and privately owned lands. You cannot let prairie dogs and coyotes 
ragin unchecked and expect the economies of tne surrounding counties to continue at a 
normal rate. 

Alternative NO. (2) as well as No. (4) is not a true evaluation of conditions on the 
game refuge and neither proposal would be of benefit to wildlife or grazing of livestock. 
The Indian and buffalo nas proven to intellegent men that grass is an increaser and browse 
is a decreaser when the grass is not properly utilized. Neither proposal allows for the 
proper utilization of grass. 

Multiple use as defined in Alternative No. (3) is not, in common sense, multiple use 
and should never have been defined so deceivingly in the existing document. 

The increase in prairie dogs cannot be justified under Executive Order 7509 which calls 
for protection and improvement of grazing lands and natural forage. 

Executive Order 7509 also 9ays that "nothing herein comtained shall restrict prospect- 
ing, locating, developing, entering, leasing, or patening the mineral resources of the 
lands under the applicable law". 

The study team determined that the federal government is subsidizing AUMs on the CMR. 

A VERY FALSE STATEMENT. The revenue into the U.S. treasury in 1979 for the 56,524 AUMs of 
grazing on- CtlR amounted to $106,830.00. The six counties involved got back $15,133*00. It 
does not include an explanation of the difference in conditions under whicn federal, state 
and private AUMs are leased to provide a fair evulation of the worth of AUMs under Diff- 
erent Landlords. 

Tne study team were incapable of giving a fair evaluation of an ADM on the CMR. They 
Considered the value of dollars taken into the FW5 only. The true value of an AUM should 
include the value to the economy of the entire nation. That value is many times the value 
taken into the F.7S. In the thousands of dollars. It must be considered on the tax basis, 
trucking to the amction market, feed lot, neat packing plant, food market and on to the 
consumers tables. That one AUM is worth a hell of a lot to the economy of our nation. 

We nave studied ETS statements after EIS statements and this is the most untruthful 
misrepresented document we have viewed. It lacks both truth and wisdom. Our recommendat- 
ion is to toss the document in the waste basket. Make a new one with no appropriation 
from Congress. 


Respec 
de^C. Childers, Pres. 


[Ubmi tted 


CC: Secretary of Interior, Cecil Andrus 
Senator John Melcher 
Senator Max Baucus 
Congressman Ron Marlenee 
Congressman Pat Williams 


Response to Garfield McCone Legislative Association 


1. The subsidy results not from a flow of federal funds ($106,830 out 
and $15,133 back), but from a resource subsidy to ranchers who re- 
ceive a AUMs worth substantially more than $1.89 to them for $1.89. 
It is this difference that generates the subsidy. 

Your concern over the $1.89 AUM is correct in that the $1.89 fee 
does not reflect the value of the AUM to the ranch operation. This 
has been corrected by adopting a linear programming (LP) approach 
to estimating the financial impacts to the rancher. 

The LP analysis estimates the change in gross income associated 
with a change in CMR AUMs. The LP measures changes in rancher cash 
expenditures, labor inputs, returns to investment, and beef cow 
inventories. The analysis does this using an average ranch budget 
for ranches of different ranch size classes. These budgets take 
into account mnerous factors including seasons of use and differ- 
ences in dependencies. This approach tailors the analysis to the 
regions and ranches by reviewing the ranch budgets with a repre- 
sentative rancher panel for the EIS area. In this case, the value 
per AUM was $12.87. 

This technique is being applied to analyze similar grazing actions 
for BLM. The National Cattlemen’s Association and Public Lands 
Council support this approach to impact assessment. See Appendix 
10 for example inputs and outputs. 


2«9 



Gi 


CHAMBER OF COMMERCE & AGRI 
AR 


asgow 


0X 832 GLASGOW. MONTANA 59230 

TELEPHONE (406) 228-2222 


Statement of position as voted upon by the Board of Directors of 
Glasgow Chamber of Commerce and Agriculture at the regular meetinq Oct 
14, 1980. y 


After study and discussion on the proposed alternatives as presented 
in the Draft Environmental Impact Statement, regarding the management of 
the Charles M. Russell National Wildlife Refuge, we the Directors of the 
Glasgow Chamber of Commerce and Agriculture find Alternative A of No 
Action to be appropriate for our support. However, a specific reference 
is made to the statement that livestock numbers would not change, yet 
under the Mitigating Measures paragraph, reference is made to portions or 
all of, the Proposed action. Intensive Wildlife Management or No Grazlnq 
alternatives. We find this statement of Mitigating Measures entirely 
unsuited to the concept of the No Action alternative. We propose if 
Mitigating Measures are required, absolutely no plan to include the 
statement of no grazing for livestock be considered, or any reduction of 
present livestock carrying capacities be implemented. 



Glasgow Chamber of Comnerce & 
Agriculture 




2100 L street, N.w. 
Washington. D.C. 20037 
(202) 452-1100 


October 31, 1980 


OFFICERS 

Coleman Burke 

Chairman oj the Board 

K. william Wiseman 

vice Chairman 

John A. Hoyt 

President 

Patrick B Parkes 

vice President/ Administration 

vice President/T reasuret 
Mur. laugh Stuart Madden 
Vice President/ 

General Counsel 
Patricia Forkan 
Vice President/Program 
and Communications 
Dr Amy Freeman Lee 
Secretary 


Erwin W. Steuke 
Area Manager 

U.S. Fish and Wildlife Service 
Room 3035 Federal Building 
316 N. 26th Avenue 
Billings, Montana 59101 

Dear Mr. Steuke, 

We are writing to express the views of the 
Humane Society of the United States concerning 
the proposed management plan for the Charles M. 
Russell National Wildlife Refuge. 


DIRECTORS 
Rosemary Bennlng 
Amanda Blake 
Samuel a. Bowman 
Coleman Burke 
Tess Cammack 
Jack Con Ion 

Anna Fesmlre 
Harold H. Gardiner 
Roben w. Gilmore 
Dr Amy Freeman Lee 
Virginia Lynch 
l)r Robert R Marshak 

Inga Prime 
Jacques V, Slchel 
k. william Wiseman 


We feel that none of the alternatives 
adequately considers or provides for all native 
wildlife. Alternative B (Proposed Action) comes 
closest to addressing this issue but, specifically, 
it is at odds with three of the CMR goals expressed 
on page 4 of the Draft EIS : 

1) To attain and perpetuate a balanced, natural 
diversity of plant and animal communities, 

6) To preserve and protect the integrity of the 
nationally significant Missouri River breaks 
ecosystem, 

10) To demonstrate and contrast management of wild- 
life through natural ecological processes. 


Alda Flemming 
Hugh John Flemming 
Virginia Mllllken 
Elsa Home Voss 
Andrew Wyeth 


Furthermore, the Proposed Action grossly 
favors management of the habitat to benefit and 
augment populations of game animals. Mule deer 
and sharp-tailed grouse are already extremely 
common, yet the bulk of the proposal is directed 
at habitat management to favor these species. 


Ociober 14-18 □ iqbi Annua) Conference □ St. Louis. Missouri 


Page 2 


We therefore propose the following modifications 
of Alternative B: 


1. Grazing not be allowed in riparian habitats. 

The extent of riparian habitats was seriously 
reduced by the creation of the Fort Peck 
Reservoir and now comprises less than 1% of 
the Refuge. These limited areas provide, in 
the words of the EIS, "most productive and 
important wildlife habitat," yet they will 
continue to sustain a "disproportionate share" 
of grazing. Riparian areas provide the nesting, 
roosting, foraging and water requirements for 
many species of animals and should be protected 
as fully as possible because of their ecological 
value as well as their rarity as a habitat type 
on the Refuge. 


Goal 8 (page 4) specifically states that grazing 
for domestic livestock be provided " when compa - 
tible with wildlife and habitat goals 11 (our 
emphasis) . Grazing would continue to threaten 
the natural state of riparian habitats and the 
animal community which is unique to them. 


2. Prescribed burning not be allowed in the pon- 
derosa pine/ juniper habitats of the Refuge. 

The theory behind such burning is to reduce 
erosion and fire hazard by maintaining a sub 
climax community. The reality is evidently 
to provide cover and food for game species; 
the size of the bums is considered optimal 
for deer and elk (page 11 of EIS). 


These coniferous communities would attain climax 
condition if such burning were not allowed (page 
62) . Climax coniferous forests would support a 
different animal community than would a habitat 
where prescribed burning maintained a more open 
canopy and dense shrub layer. Songbirds such as 
juncos, red crossbills, pine siskins, mountain 
chickadees, western wood peewees, western tanagers, 
and Townsend's solitaires, which prefer denser coni- 
ferous habitats would be encouraged. The Proposed 
Action alternative favors the maintenance of serai 
communities, at the expense of climax communities, 
because these tend to be more productive of food 
and cover for game species. 


2 


Page 3 


Goal 5 (page 4) is to "manage migratory 
bird habitats." If "migratory birds" is to be 
taken literally, then the coniferous forests 
must be managed to benefit the many migratory 
songbird species which depend on that habitat. 

If, on the other hand, "migratory birds" is used 
in its limited, game management sense (i.e. 
waterfowl) , then no provision is made in the EIS 
for the majority of the 245 avian species found 
on CMR (only 15 percent are resident species) . 

Obviously, in this area of Montana there is 
a limited variety of habitat types. In general 
we believe that for the sage and grassland habitats, 
Alternative B would encourage a diversity of both 
game and non-game species which utilize these open 
habitats, even though the basis of the proposal 
is to create conditions favorable to ungulates 
and game birds. However, game species should not 
be given priority in every habitat type; in certain 
habitats, the requirements of game animals are 
different from those of non-game animals. The 
emphasis on development of shrubs in all habitat 
types serves to create an artificial, uniformity. 

We believe that with the incorporation of our 
modifications (1. No grazing in riparian habitats, 

2. No prescribed burning in the ponderosa pine/ 
juniper habitats) , Alternative B would then be 
consistent with the purported goal (#1) of the Refuge 
to "Attain and perpetuate a balanced, natural di- 
versity of plant and animal communities." 


More than ever before the American public is 
showing a strong interest in the non-consumptive 
benefits of wildlife. With the recent passage of 
the Non-game bill, official conservation agencies 
are finally initiating programs centered on non- 
game wildlife. We hope these changing attitudes 
toward managing for entire communities and habitats, 
instead of giving priority to a few commercially 
valuable species, will play a larger part in the 
management of the CMR Refuge. 

Sincerely, 

Natasha Atkiits Patricia Forkan 

Wildlife Biologist Vice President 

Program and Communications 



266 




Response to the Humane Society of the United States 


1. During the habitat evaluation procedure survey (Appendix 2) of the 
refuge, it became apparent that many species had similar habitat 
requirements. Rather than selecting an animal with little litera- 
ture data available and not easily recognized by the public, mule 
deer and sharp-tailed grouse were selected among others. The 
habitat components of these animals fit the habitat component 
necessary for a large number of non-game wildlife. 

2. Under the Proposed Action, riparian habitat on level land close to 
water will receive light to moderate livestock grazing pressure. 
Elsewhere on the refuge, this important wildlife habitat component 
will receive little or no livestock grazing. 

3. Prescribed burn programs are not intended to alter significant 
portions of the coniferous communities to serai stages, but to 
provide a habitat diversity originally occurring before wildfire 
control. Prescribed burns will aid in the establishment of the 
deciduous shrubs and will provide a diversity of habitats for all 
wildlife species, both game and non-game alike. 

4. CMR will be managed for habitat diversity which will provide for 
avian diversity. 



LAST CHANCE AUDUBON 
SOCIETY 


Helena, Montana 59601 
November 7, 1980 


Mr. Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3035 
316 N. 26th St. , 

Billings, Montana 59101 


Dear Mr. Steucke: 

Y»e appreciated your speaking to the Montana 
Audubon Council in Billings in September. You 
outlined the alternatives clearly and I felt your 
environmental impact statement was well done, clear, 
and concise. 

We wish to go on record as approving alternative 
B, the proposed action. It is clear from your state- 
ments and from what I know of that area that more 
wildlife cannot be managed. We hope the grazing in 
over grazed areas can be managed so that the land 
can again be productive. I went to a hearing in Helena 
lasg January at which some ranchers admitted the over- 
grazing. We recommend alternative B. 

Sincerely, 


u 




4 


Martha A. Hassell, President 
Last Chance Audubon Society 


Sis 




V* 


of these species to C.M.R. the restrictions on hunting could be & • fa) 


The Lewistown Bowhuntera Association, consisting of eighty five 


controlled by many nature groups who strive to protect endangered J5r " ft 


members, would like to provide the following input to your draft 


species. Once an endangered species is introduced to an area _5. ll 


E.l.S. We hope you will consider our questions and, if needed, LEWISTOWN 


trapping is halted, and control could begin on hunting. If LEWISTOWN 


furthur analiae the impacts that we feel have not been sufficiently ASSOCIATION 


protectimist groups decide that hunters could become a deterent ASSOCIATION 


addressed. They are as follows: uwromnomwiiui 


to these species, they could insist on closures to hunting in 


(1) Hoad Closures. 



this particular area. As the endangered species begins to thrive 


We feel that furture road closures would add to the growing concern of 



and expand it's territory, so could these controls. With this, we 


concentrated hunting pressure on the C.M.R. Therefore, we recommend that all 

i 


feel that our hunting rights are being infringed apon and thus 


present and existing roads be open for use. This would relieve some hunting 



harvest objectives are not met. 


pressure and aid in a better harvest for archers. 



We feel the impacts from the intoduction of threatened or endangered 


(2) Game Retrieval. 



species is not sufficiently addressed and must consider future hunting 


We would like to see some changes in the game retrieval regulations on 



and trapping closures. 


the C.M.R. Refuge. We reccomend that a C.M.R. selected individual or individuals 



(5) Elk management. 


be made accessible at Slippery Ann Station in order to facilitate downed game 



As stated in the Draft Enviromental Impact Statement pg. 44 " Adjacent 


removal by accoopaning or giving written permission to drive as near as possible 

2 


landowners and grazing permittee attitudes are negative towards this expansion 


to the downed elk or deer. This will decrease the chance of wasted meat. There 



( of elk herd ) and poaching and illegal shooting could limit furthur expansion 


are variables that are difficult access when considering the probability of 



of their ( elk ) range." Also stated is: " ^he present elk population level 


successful animal removal. That is, for example, it is difficult to determine 



in the breaks ecosystem ( on and off refuge ) is at a level ( approximatly 


early in the morning wheather the temperature at ten will be 60 or 110 degrees. 



13OO-15OO ) that can be tolerated by the ranching community. 


(3) Elimination of the alfalfa bottoms. 



It has been shown th*t bowhunting is an effective management tool in the 


w e feel that the cultivation of the fertile bottoms for fbrage crops should 



C.M.R. range. Ref: 1979,1980 archery seasons. 

5 

continue. The us of these alfalfa and gr a in fields by wildlife is obvious to 



We suggest that the population of the elk herd remain in the area of 1300- 


anyone who views them. The impact to the farmers involved is obvious, though 



1500 animals in the C.M.R. ecosystem. This will keep an exellent working 


not discussed in the E.l.S. But the impact on the wildlife involved is hard to 



relationship with the ranchers in the area of the C.M.R. ecosystem which is 


quantitavely assess and could be highly detremintal to their survival. We 

3 


vitally needed to produce harmony with the people in Central Montana. If the 


admit that thiAr presence does not enhance the rugged beauty of the Breaks, but 



elk herd were to expand beyond the tolerated 1300-1500 animals, we suggest 


neither does the signs, buildings and other man made infringements upon this land 



that special hunts be held for bowhunters. Example: late season hunts, longer 


that will remain. This vital forage should remain as long as a sizable portion is 



seasons and special area hunts. Bowhunting, as stated earlier, is a effective 


left for the use 6C the wildlife of untill such time as it is poeitivly shown 



management tool. It could be used realistically for a balance of herd, and 


that it's use is of no use to the wildlife or the C.M.R. 



moat importantly, as a tool for a working relationship with ths ranchers in 


(4) Endangered or unique species. 



the C.M.R. ecosystem. 


We are against the introduction of endangered or unique species on the 



(6) Water developments. 

L 

Charles M. Russell National Refuge as discussed in the propossed actim. This 

A 


We feel that water developments could be used as a grazing management 

r 

introduction could have a very serious impact our recreational use of the C.M.R. 




The impact of new species introduction needs to be carefully assessed and mitigated 




to prevent conflicts with legitimate refuge associated activities. By introduction 







3 

tool. It seen s an added emphasis on the construction of reservoirs, 
pits or water savers, in suitable areas, would decrease the intense 
pressure of concentrated animals. 

Several years ago the JVS considered such developnents at a 
number of sites, using Soil Conservation Service criteria as 
guidelines. A number of sites were approved, while many were dropped uwaT0n " 0,^A,um, ' 
from consideration. Vhile good water development sites are not easily found 
in the C.M.H. There are sites suitable for water developments eaen though 
they do not meet SCS criteria. As funds become available, additional water 
developments would be an exellent management tool, and in no way would deter 
from wildlife management priorities. 

(7) Accuracy of the Draft Enviormaental Impact Statement. 

We feal‘bk*ttthef,atghtsseer use as stated may in fact be hunters or 
fisherman in pre-season scouting. Statements written out on page 209 are hard 
to believe. We feel these figures should be substantiated and the bowhunter 
hours depicted. W e f©«i from April to Octtober sportsfisherman are the main users 
because of the success in the area. The months of July to September are used by 
hunters locating and scouting potential areas for hunting. The months of November 
through March are used coyote hunters and trappers. Figures show that over 600 
permits were issued for coyote hunting. 3&5 permits were issued to gun elk hunters, 
and 1400 archery elk permits were issued by C.M.R. In summary, we feel that many 
of these sight seers etc. are actually hunters and this should be further substantiated 
and assess the impacts. 

(8) Summary 

In summary, the L.B.A. feels that the impacts to bowhunting have not been 
suffeciently addressed. We do, however, feel that Alternative D, Multiple Use, 
is the most logical and fully support it as the alternative to be selected. 



LEWIS TOWN 

BOWHUNTERS 

ASSOCIATION 


a 


Response to Lewistown Bowhunters Association 

1. 

Several hundred miles of designated roads exist on the refuge. 
Those suitable for continued use will remain open, while those 
susceptible to landslides, washouts, or wildlife conflicts may be 
abandoned or changed. Essentially, the road pattern as shown on 
the CMR road map will remain the same. 

2. 

Regulations allow the retrieval of game by boat or horse. Vehic- 
ular travel is restricted to designated roads, primarily due to the 
fragile environment of CMR. 

3. 

The decision to manage in a "generally natural setting" is in 
accordance with FWS legislative mandates and policies. This phi- 
losophy of management precludes undue disturbance in the river 
bottoms. The FWS acknowledges that this decision will affect the 
abundance of some common wildlife species that require agriculture, 
but the riparian habitat which will replace the cropland is much 
more valuable to a greater number of wildlife (including deer and 
elk) . 

4. 

The Endangered Species Act does not preclude hunting, fishing, or 
any other form of recreation when these activities do not jeop- 
ardize the continued existence of these species or result in the 
destruction or adverse modification of their critical habitat. 

5. 

The FWS does not propose a dramatic increase in deer and elk popu- 
lations. The improvement and maintenance of habitat capable of 
supporting an overwintering population of 2.5 elk/sq.ml. in suitable 
habitat is the objective. 

6. 

The decision to manage in a "generally natural setting" is in 
accordance with the FWS legislative mandates and policies. This 
decision precluded further water development except where specifi- 
cally mentioned in the text. Further, in examination of HEP values 
compiled on allotments on the refuge, it has been concluded that i 

additional water development would be detrimental to most wildlife 
species in that it would distribute livestock into areas now used 
almost exclusively by wildlife and that are needed by wildlife. 

7. 

Based on available information (FWS visitor use and preference 
survey conducted in 1978), it is presently not possible to deter- 
mine what percent of sightseer use (viewing scenery and exhibits) 
may be attributable to hunters and fishermen. Additional studies 
may be needed to measure such use. 

8. 

The CMR now provides some of the highest hunter success bowhunting 
for elk in the nation and good hunting for deer. Results of the 
Proposed Action would, over a period of time, tend to improve this 
success. 


MILES CITY 

AREA ( l 


Miles City, Montana 59301 



Erwin W. Steucke 
Pish A Wildlife Service 
Federal Building Roam 30^5 
Billings, Montana 59101 


Re i Charles M. Russel National Wildlife Range 
Dear Mr. Steucke: 

On behalf of the Miles City Area Chamber of Ctanerce Board of Directors, 
I would like to take this opportunity to express our sincere objection 
to any move to cut livestock range area. 


The Ranohe r/Parme r play a vital part in Montana's future, growth, and 
economics. With this in mind, we wish that no action be taken in 
regards to the Enviromental Impact Statement. These lands are very 
important to the Ranchers and Montana's growth. 


Eastern Montana needs your support for our growth. Please go with 
Alternative n A" - the no action plan, or the multiple use plan. But no 
cuts in livestock grazing by lengths of season or by numbers. 


CC : Senator John Melcher 

Representative Ron Marlenee 
Governor Tern Judge 


GH/as 



In oottSg copttcu? iMantana 


, v ^onOf Co^ 

a X 

November 21, 1980 


Area Manager 

U.S. Fish & Wildlife Service 
Room 3035, Federal Building 
316 North 26th Avenue 
Billings, Montana 59101 

Re: Comments on the CMR Wildlife Refuge DEIS 

The Montana Association of Conservation Districts would 
like to go on record in support of Alternative A (No action) . 
Alternative A has provided a workable plan, that includes 
several federal and state agency land holdings along with 
private land holdings and allotments in the area. There 
have been problems that come about with the present system, 
however most of these problems have been solved with proper 
communication between agencies and the private individuals. 

It is also felt that Alternative D (Multiple Use) is covered 
by Alternative A. 

Alternative B (Proposed Action) is totally unacceptable 
by the Conservation Districts. This alternative will reduce 
grazing by 33 percent occurring by 1985 with additional reduc- 
tions proposed if wildlife objectives are not reached. The 
present planned reductions could result in at least six oper- 
ators being forced out of business along with a loss in income 
of 134,000 to the federal government. A statement on page 79 
states that the loss of livestock related income is insignifi- 
cant on a regional basis. Whenever the U.S. Fish & Wildlife 
Service can remove a minimum of six livestock operators from 
business I would consider this anything but insignificant. 
Welfare recipients, who pay no taxes, are treated like kings 
by the government however individuals whose ancestors and them- 
selves have worked the land and managed to survive everything 
including the paying of taxes to support the government are 
classified as insignificant. 

Alternatives C & E are totally ridiculous and should not 
even be considered. 




7 Edwards 

Helena. Montana 59601 


\ 


Area Manager (U.S.Fish & Wildlife Service) November 21, 1980 

Page 2 


Alternative D is being covered under the present system 
to a successful degree. 

Thanks for the opportunity to comment on the Draft EIS 
on Management of the CMR National Wildlife Refuge. 


Sinp«£ly 

D aw 


Ray Beck 
Executive Vice President 


RB :dv 


MONTANA ASSOCIATION OF STATE GRAZING DISTRICTS 
7 Edwards, Helena, Montana 59601 
443-5711 

November 21, 1980 


Area Manager 

U.S. Fish & Wildlife Service 
Room 3035, Federal Building 
316 North 26th Avenue 
Billings, Montana 59101 

Re: Comments on the CMR Wildlife Refuge DEIS 

The Montana Association of State Grazing Districts 
would like to submit the enclosed resolution, which was 
passed at the Grazing Districts Convention on October 15, 

1980, as testimony of the over-all feelings and concerns of 
Montana's 30 State Grazing Districts. 

As the Draft Environmental Impact Statement now stands 
and if a rewrite is not considered the Montana Association 
of State Grazing Districts are in favor of Alternative A. 
Alternative A has provided a workable plan, that includes 
several federal and state agency land holdings along with 
private land holdings and allotments in the area. There 
have been problems that come about with the present system, 
however most of these problems have been solved with proper 
communications between agencies and the private individuals. 

It is also felt that Alternative D (Multiple Use) is covered 
by Alternative A. 

Alternative B (Proposed Action) is totally unacceptable 
by the Grazing Districts. This alternative will reduce grazing 
by 33 percent occurring by 1985 with additional reductions 
proposed if wildlife objectives are not reached. The present 
planned reductions could result in at least six operators 
being forced out of business along with a loss in income of 
134,000 to the federal government. A statement on page 79 
states that the loss of livestock related income is insigni- 
ficant on a regional basis. Whenever the U.S. Fish &. Wildlife 
Service can remove a minimum of six livestock operators from 
business I would consider this anything but insignificant. 
Welfare recipients, who pay no taxes, are treated like kings 
by the government however individuals whose ancestors and 
themselves have worked the land and managed to survive every- 
thing including the paying of taxes to support the government 
are classified as insignificant. 

Alternatives C & E are totally ridiculous and should 
not even be considered. 


Area Manager, US Fish & Wildlife Service November 21, 1980 

Page 2 


Alternative D is being covered under the present system 
to a successful degree. 

Thanks for the opportunity to comment on the Draft EIS 
on Management of the CMR National Wildlife Refuge. 



Executive Secretary 


RB :dv 

cc: Senator Max Baucus 
Senator John Melcher 
Representative Ron Marlenee 
Representative Pat Williams 


MONTANA ASSOCIATION OF STATE GRAZING DISTRICTS 

, Adopted: 10/15/80 

RESOLUTION NO. 

C. M. Russell - Environmental Impact Statement 

WHEREAS, the Environmental Impact Statement on the 
C. M. Russell Game Range is totally inaccurate of the 
sentiment of livestock industry; and 

WHEREAS they have not recognized obvious problems, 
such as unfenceable areas, over population of prairie dogs, 
and also the need of livestock industry for relative 
stability . 

THEREFORE BE IT RESOLVED that the Montana Association 
of State Grazing Districts recommend a complete rewrite 
of the draft Environmental Impact Statement on the Charles 
M. Russell Game Range. 


?W 


HEARING STATEMENT 


Response to the Montana Association of Conservation Districts and the 
Montana Association of State Grazing Districts * 

* The comment letters from these two organizations are almost Identi- 
cal; therefore, they will be responded to as one. 


1. The regional economic effects are insignificant because the relative 
change on the six county area is a very small percentage change. 

Thus to the region, there would be no perceptible change in key 
economic variables such as employment or income as a result of 
these alternatives. The absolute effect to a few individuals, as 
measured without reference to the size of the six county area, may 
be large. While this change is important to these individuals, it 
does not seriously affect the human environment of the study area 
because the absolute changes have a small relative effect. 


BY : THE MONTANA CHAPTER OF THE WILDLIFE SOCIETY 

TO: U.S. DEPARTMENT OF INTERIOR, FISH AND WILDLIFE 

SERVICE 

SUBJECT: CMR - DRAFT ENVIRONMENTAL IMPACT STATEMENT 

The Montana Chapter of the Wildlife Society is a state subdivision 
of a national organization of practicing wildlife professionals 
with approximately 150 members throughout the state. Most mem- 
bers are employed by conservation agencies. Since this proposal 
addresses some wildlife problems in one area of the state, we 
appreciate this opportunity to provide constructive criticism 
of the draft EIS. 

We consider the CMR to be extremely valuable. It is the largest 
piece of real estate in Montana with wildlife as its primary 
objective. In terms of numbers and variety of wild vertebrates 
it is likely the richest contiguous one million acres in our 
state. The refuge is unique because it is adjacent to about two 
million acres of public land managed by the Bureau of Land Man- 
agement, an agency with a mandate to consider wildlife production 
as one of its multiple use objectives. The CMR is also unusual 
because of the low human population in the area and except for 
Ft. Peck Dam and its reservoir, the area is relatively undeveloped. 
It is possible to circumscribe an area around the CMR the size 
of New Jersey with a human population of less than one per square 
mile with a variety of mostly native plant communities. In all, 
the CMR survives as one of the largest shortgrass ecosystems in 
the U.S. 

At this time the CMR is not an island of wildlife habitat. It 
is closely tied to the surrounding country and its wildlife condi- 
tion is to a large extent dependent on this tie. Political 
pressures and administrative temptations to "stake out" the 
"CMR Wildlife Ranch" should be moderated by considerations of the 
CMR being part of a much larger wildlife environment. In time, 
human population and economic development pressures will probably 
isolate the CMR, but that time is at least several decades away 
and hopefully present refuge land and wildlife managers will be 
mature, professional, and sophisticated enough to take advantage 
of the current situation. 

According to all available information, the combination, number, 
and variety, of vertebrates using the CMR is greater now than 
any time this century. This situation, it should be remembered, 
is not a result of any one wildlife management effort but more 
of a function of soil, water, climate, human population and 
economic conditions and an unusual number and variety of wildlife 
living areas which are in part the unconscious result of a lot 
of different, independent, small management efforts. There is a 
danger that a unified and homogenized management program will, 
again, unconsciously function to limit this number and variety 
of living areas thus restricting the wildlife resource. Guarding 


Hearing Statement 
Page 2 


the richness of the existing wildlife resource and protecting 
the naturalness of the area should be the first priorities. 

There is a great need, more than ever before, for federal land 
managers to consult with local and state economic, agricultural, 
and wildlife interests. Management programs must be made some- 
what consistent with local needs and desires. 

We are not opposed to grazing on the CMR. As a matter of fact, 
we support livestock grazing as an consistent economic use of 
the vegetation resource. We are opposed to those actions, 
including livestock grazing, which damage the natural ecosystem, 
reduce the wildlife potential, or damage other public values. 

We believe that livestock grazing capacity should be determined 
by the grazing available on upland plateaus and benches. Coulees, 
sideslopes, and other steep terrain constitute the main deer and 
elk habitat and soils and vegetation in these areas are easily 
damaged by overgrazing. 

In part II., Alternatives, we support most of the CMR goals (p.4). 
We are, however, skeptical about some things that may be included 
in Goals 4, 5, and 10. The term "goals" used in Goals 3, 8, and 9 
should be called objectives . 

We support the wildlife objectives (p. 5). However, since sage 
grouse and antelope use much the same habitat, sage grouse should 
be included in No. 5. The list should be extended to include a 
No. 12 for species of special interest which could include: blue- 
bird, upland plover, mountain plover, poorwill, osprey, and 
possibly others. 


In the range objectives. No. 1 states "Improve climax range condi- 
tions." The government has great power, but this can't be done! 
You may be able to improve present range condition toward climax. 


I 3 


ALTERNATIVE B (PROPOSED ACTION) 

The Montana Chapter supports the goal of improving vegetation to 
enhance wildlife habitat. However, since this porposal depends 
heavily upon permittee's compliance with the terms of their graz- 
ing permits (livestock numbers, grazing season, and pasture manage- 
ment patterns) , failure in this area negates the entire plan. 
Although CMR presently attempts to deal more strongly with non- 
compliance, the livestock management plans are a paper exercise. 
Without permittee compliance, this plan reverts to Alternative A 
(No Action) . 


ALTERNATIVE A (NO ACTION) 

This proposal may be second best for wildlife, mainly because we 
know what is there now. If the many problems of compliance were 


Hearing Statement 
Page 3 


corrected under this alternative, there would be some vegetation 
improvement and wildlife benefit. The most serious consequence 
of this proposal is the continued deterioration of already 
damaged sites, mainly resulting from livestock management. We 
would prefer a fire control policy that would put better guide- 
lines on which fires to fight and which to let burn themselves 
out. 


ALTERNATIVE C (INTENSIVE WILDLIFE MANAGEMENT) 


We are opposed to the fencing of the entire refuge boundary in this 
alternative. The grazing reductions appear to be greater than 
necessary to provide wildlife habitat. The intensive farming 
plan also violates the natural ecosystem guideline. We would 
be opposed to 38,000 acres of soil ripping on the same basis. 

ALTERNATIVE D (MULTIPLE USE) 

Supposedly the multiple use option and the no action option are 
not very different. The most damaging part of this proposal is 
the control exerted by livestock permittees over the use of forage. 
Most of the current problems are the result of one-sided policy 
favoring livestock use. Again, unless there is better control 
of permittee compliance, things out there on the ground would 
no change that much. 

ALTERNATIVE E (NO GRAZING) 

Without some prior study to indicate the need, we are opposed 
to a plan of prescribed burning. Soil ripping in this proposal 
is not necessary. We reiterate our support of grazing as a 
beneficial use of the vegetation resource. 

OTHER COMMENTS 


1 . We have serious reservations about the ability of the FWS to 
enforce permittee compliance with the conditions of their grazing 
permits . 


h 


2. We have reservations about the results of the range survey 
that is the basis of the vegetation planning. The vegetation 
results have to be biased due to the above normal precipitation 
preceding the survey. Specified procedures were not followed in 
estimating vegetation production. The standards used in the 
survey may not be applicable to the area surveyed. Very little 
clipping was done to verify estimates. The relation between 
Appendix table 8-A and 8-B give virtually no indication of how 
the survey supports either the theoretical (8-A) or the actual 
(8-B) production and should be dropped from the final report. 

The range condition classes appear to be too high, primarily due 
to the extra weight given to robust perennials which provide 


Hearing Statement 
Page 4 


the aspect of more vegetation that was actually there. 

4. We have reservations about the system of planning. This 
seems to be a cart-bef ore-the-horse situation. The logical 
method would be to determine problems, provide a plan to correct 
the problem or a study to provide needed data to plan the cor- 
rection. There is a general lack of planning to study problems 
to determine workable and successful solutions. Many of the 
problems are controversial, mainly due to the lack of information 
which can be accepted by both sides, and the only permanent solu- 
tion will have to be based on better information. 


I B 

0 


5. We support rest-rotation grazing as a method of restoring 
vegetation where it is damaged and in those places where it is 
demonstrated to be superior to a deferred rotation system for 
maintaining wildlife habitat. Stubble height requirements appear 
to be too high. Much of the vegetation never attains the stubble 
minimum. Water developments should be fenced and 3 or 4 water 
tanks placed on ridges away from the reservoir, these tanks to be 
rotated yearly or seasonally to reduce the trampling and trailing 
damage to the vegetation near water sources. 


7 

8 


6. We support a plan which provides professional study of specific I 
wildlife benefit programs, before they are implemented and after |9 
they are completed. 


7. We would support a plan which would restore the productivity 
of the larger coulee bottoms, reduce gully erosion, and provide 
wildlife habitat. 


8. Endangered species introductions should be coordinated wit^h 
existing wildlife programs, handled quietly with a minimum of 
management adjustments. Focusing attention on this aspect of 
refuge management at this time does not seem to be in the interest 
of the endangered species. 

9. Elk and deer stocking rates should depend on conditions sur- 
rounding the CMR as well as habitat conditions within the refuge 
boundary. In this area coordination with state and local private 
interests is most important. 


dluj&y. 1 L " S 

Mr ivcJbeA Pre* 

P r \o*N.V o-w**. TVkiS 

LjCrs ^ 

K»Vnp*l\ ,M+ s'? 9o/ 


Response to the Montana Chapter of the Wildlife Society 

1. 

A goal that is normally expressed as a broad, general statement is 
usually not quantifiable, and is timeless in that it usually has no 
specific date by which it is to be completed. 

An objective is measurable and implies precise time-phased steps to 
be taken and resources to be used which, together, represent the 
basis for defining and controlling the work to be done. 

2. 

The Executive Order mandates a specific objective for antelope and 
sharp-tailed grouse, and FWS feels it must manage specifically for 
these species. Additionally, by managing for habitat diversity, 
we believe we are providing for a wide diversity of wildlife species. 

3. 

The FWS agrees; the text has been amended. 

4. 

Upon further analysis, FWS determined that only about 300 miles of 
the 440 mile boundary would need to be fenced under the Intensive 
Wildlife Management alternative. See amended text. 

5. 

It is the intent of the FWS to enforce all rules and regulations 
including conditions on grazing permits. 

6. 

The range survey was done by four highly competent range special- 
ists. We admit the survey was done during an above normal precipi- 
tation period (see paragraphs 1 and 2, page 172 ). However, SCS 
procedures for range surveys are designed to take this into account. 
The 100-plus years of experience of the persons conducting the 
survey guided them in their decisions. 

FWS believes Appendix Tables 8a and 8b do provide data that is of 
value. They provide the reader with a guide as to what can be ex- 
pected on the refuge under varying conditions. 

7. 

Please see Appendix lb (not available in the DEIS) for a review of 
the planning process used for CMR. 

8. 

The residual cover heights were taken, in part, from original 
sharp-tailed grouse research done in Nebraska by Sisson. Mr. 
Sisson is acknowledged as an authority on the habitat of sharp- 
tailed grouse. These stubble height criteria will be applied only 
to range sites capable of producing the required stubble heights. 

9. 

This practice is good in theory. However, it is very expensive, 
presents numerous mechanical problems, and detracts from the 
naturalness of the area. 


Professional studies on specific wildlife programs have been done 
in the past, and will be done in the future, as funds and manpower 
permit. 


The FWS will work 
coordinating with 
actions on CMR. 


:o achieve it6 objectives while concurrently 
•ther agencies and individuals impacted by 



Montana Natural Resource Clinic 


School of Law 
University of Montana 
Missoula, Montana 59812 
(406) 243-6500, 243-4312 


Carl W. Tobias, Director 


September 22, 1980 


Don W. Minnich 
Regional Director 
Fish & Wildlife Service 
USDI 

P.0. Box 25486 
Denver Federal Center 
Denver, Colorado 80225 

Dear Mr. Minnich: 

I appreciate your taking the time to talk with me on Friday about the timing 
of the public hearings on the C.M. Russell management plan and your willingness 
to speak with the Area Manager about the problem. Regardless of the resolution 
of this problem, we do look forward to working with the Service on developing 
the best plan possible. 


Thank you for your help. 


CWT/rp 


Sincerely, 


Carl W. Tobias 
Associate Professor 


Sponurtd by o Grant from the NATIONAL WILDUFE FEDERATION 


271 



MS TOM STOCHGROWERS ASSOCIATION, INC. 

P. 0. BOX 1679 - 420 NO. CALIFORNIA ST. - PHONE 14061 442 3420 - HELENA. MONTANA 59601 



December 9, 1980 


Erwin W. Sieucke , Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 No. 26th St. 

Billings, MT 59101 

Dear Wally: 

Please place the Montana Stockgrowers Association on record in 
support of the comments submitted November 13, 1980 by C.E. Hitch 
of the Montana Public Lands Council on the draft environmental impact 
statement for the C.M. Russell National Wildlife Refuge. His assess- 
ment of this document is detailed and is in complete accord with my 
views on the draft EIS. 


I realize this comment is a bit late, however, I have been out 
of the office until just this week and was unable to get to it earlier. 

Thank you for allowing us to comment in this fashion. 


MLT:mlt 


Sincerely yours. 



SERVING MONTANA S CATTLE INDUSTRY SINCE 1884 


MONTANA TRAPPERS ASSOCIATION 

BOX 29 

SEELEY LAKE , MT. 59*68 

Working today -for a tomorrow in trapoinq 
Furbearers are a RENEWABLE NMUftol RESOURCE 

November 15, 1980 


Ralph Fries, Refuge Manager 

Charles M. Russell National Wildlife Refuge 
Airport Road 
Lewistown, MT, 59457 

Dear Ralph; 

The Montana Trappers Association has reviewed the Environmental 
Impact Statement for the management of the Charles M. Russell National 
Wildlife Refuge. Relevant to that our Board of Directors have 
passed unanimously the following resolution which we would like 
to have implemented in the management plan. 

Whereas the U.S. Fish and Wildlife Service has statutory 
authority for the management of all species of wildlife on the 
Charles M. Russell Wildlife Refuge, and 

Whereas the U.S. Fish and Wildlife Service has in the past 
largely ignored most furbearers and their management on the Charles 
M. Russell Wildlife Reijuge, and 

Whereas the U.S. Fish and Wildlife Service is presently 
considering a master management plan for the Charles M. Russell 
Wildlife Refuge, be it 

Resolved that the Montana Trappers Association urges the U.S. 

Fish and Wildlife Service to open the Charles M. Russell Wildlife 
Refuge to trapping of all furbearers and predatory animals on a 
species and site specific management program. 

Your consideration will be appreciated. 

Sincerely, 

Edd Nentwig, President 
EN/CDS 



Response to Montana Trappers Association 


1. One of the primary objectives of FWS management Is the protection 
of wildlife and its habitat. Future furbearer trapping will be 
considered in light of refuge objectives, FWS policies, and appli- 
cable federal laws. 


3318 Sundance Drive 
Bozeman, Montana 59715 
December 2, 1980 


Mr. Erwin W. Steuke, Area Manager 
U.S. Fish and Wildlife Service 
Room 3035, Federal Building 
316 North 26th Avenue 
Billings, Montana 59101 

Dear Sir: 


I am writing you with comments on the draft environmental impact state- 
ment for the Charles M. Russell National Wildlife Refuge. In general I 
would agree that your proposed alternative B offers the most benefits 
for wildlife in the long run. However, I believe that there are some in- 
herent conflicts between your stated Congressional mandates and some of 
your proposals for action in alternative B. Specifically, the ripping, 
planting, and spraying that you propose over as much as 10,000 acres of the 
CMR refuge will not result in a generally natural setting for wildlife. 

Nor will the inclusion of existing cabin sites result in a natural setting. 
I believe that the inclusion of recreational homesites on a national wild- 
life refuge is an incompatible and inappropriate use of the area and would 
recommend phasing these cabins out entirely. 


I agree with your objectives of gradual reduction in livestock grazing, 
phasing out farming in the Missouri River bottomlands, and the consolidation 
of land ownership. However, I do not believe that all natural fires should 
be suppressed as they provide an important component in maintaining the 
refuge in a generally natural setting. 




The same objection applies to the large scale predator control on the CMR 
refuge. Natural predators form an integral part of the wildlife population, 
and I do not believe that predators should be killed just to benefit the 
livestock grazing on a national wildlife refuge. Instead, predators should 
be controlled only in extreme cases, where endangered species need protection 
or in similar situations to enhance wildlife. I commend your plan to re- 
introduce the black-footed ferret, the peregrine falcon, the swift fox, and 
bighorn sheep. 

Some of your plans for enhancing recteational opportunities in the refuge 
can only be viewed with alarm, especially the possible introduction of 
additional boat launching and float plane landing sites. Wherever funds are 
limited, the preservation and enhancement of wildlife values should take 
highest priority, especially in areas like the CMR refuge, where so much 
deterioration by overgrazing of both cattle and sheep has been allowed to 
occur. Your proposed alternative B at least is a beginning step in addressing 
these problems for the benefit of wildlife. 


Sincerely you rs , 

Ann Sutton, vice President 
Montana Wilderness Association 


272 


Response to Montana Wilderness Association 


1. Please see responses to Defenders of Wildlife. 


EDUCATION - CONSERVATION 


“THontotUL TViidlCfie ^edenatcoK 

AFFILIATE OF NATIONAL WILDLIFE FEDERATION 


Brwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building 
Billings, Mt. 59101 



12/4/80 


Dear Mr. Steu^kei 

Attached are the written comments of the Montana Wildlife 
Federation on the C.M. Russell draft environmental Impact statement. 
Our organization represents over 1800 sportsmen and women in Montana, 
who have a keen interest in preserving wildlife, habitat and our 
sporting heritage. 

I would be very willing to discuss an/ of our comments or an/ 
other comments on the DBIS with you or your staff whenever you feel 
It would be both helpful and productive. Our organization stands 
ready to assist in the preservation and maintenance of Montanas' 
wildlife resource whether on or off the C.M. Russell Wildlife Refuge. 

If I can be of any further assistance please feel free to call. 


Sinoerely fours, 

'Wf/lOUr ftj. 

Wilbur w. Rehmann 
Bxeoutive Direotor 
Montana Wildlife Federatio 


‘ v. 



The Montana Wildlife Federation supports the Fi3h and Wild- 
life Service eleven goals as outlined inthe DBIS, but we question 
the lack of specific details to achieve those goals. In fact, 
most of the goals, wildlife objectives, range objectives, and re- 
oreation objectives offer little supporting evidence or data. 
Further, many of the objectives appear as if they w ere chosen 
arbitrarily. We expect to seemore evidence, either in a supple- 
ment, which has already been oalled for, or in an expanded final 
environmental impact statement. 

The Federation oompllments the Servioe for undertaking this 
monumental task of planning on the CMR, but we are disatisfled with 
the BIS for the following reasons i 

1. The BIS is grosssly inadequate in its exploration 
of management alternatives. 

2. Tftere is an implied absolute confrontation between 
grazing by domestic livestock and wildlife which is 
unjustified. That confrontation seems to permeate 
the entire document. 

3. The Federation objects to the use of meohanioal 
range renovation, such as soil ripping, plowing, 
burning and furrowing as a management technique. We 
believe this oonfliots with the Services' goal of 
"naturalness" . 

4. There is very little discussion of sport hunting and 
fishing as either a recreational resouroe or as a 
management tool. Further, what objectives must be met 
before hunting or fishing will oocur? 






5. The economic analysis is more of a 'guestimate* 
than sound soientifio analysis. Further data should 
be supplied and more sophisticated techniques should 
be used in order to more accurately predict both the 
costs and benefits. Are you in fact going to put six 
ranohing operations out of business, no more, no less? 
Your eildenoe is very slim. 

6. Is 'naturalness* really going to be adhered to. or are 
other objectives such as the myriad introduced species 
and pen/pasture program going to give the CMR a "zoo- 
like ' look? 

The Federation strongly feels that wildlife and wildlife habitat 
must reoeive primary attention both in the BIS and on the ggound. 

All of the alternative management plans appear to be very ganaral 
and foous heavily on lives took-range management rather than meeting 
speoifio wildife, habitat, or reoreational goals. 

To imply that any AUM taken away from livestock will automatically 
be used as food or cover by wildlife would be difficult if not 
impossible to demonstrate. 

We support the reintroduotion of endangered species suoh a s 
blaok-f ooted f.rr.ts, p.r.grln. faloona, and swift fox, but we question 
th. wisdom of transplanting big-hor. sheep alno. previous .fforta 
have been largely unsuooessf ul . 




Th. .limination of farming op.ratlons along th. Missouri River 
is anoth.r positive step. Along with suoh measures sp.olfio method. B 
of ..-establishing riparian habitat should be mor. thoroughly disoussod. 


273 


We also support management of predators, Including bunting 
and trapping. There should be more discussion of this controversial 
issue in the BIS. Predator control may be absolutely necessary 
if they cause damage to domestic livestock off the Refuge, and on. 

We propose that the Fish and Wildlife Service oonsidor the 
f oil owing i 


9 


1. Rest-rotation grazing be implemented on any area on 
the CMR now grazed by livestock or on any aroa pre- 
viously grazed by livestock that needs range improve- 
ment. All rost-rotation plans must be coordinated 
and implemented with adjacent public and private 
landowners . 

2. Continuous grazing, even at moderately reduced ratos, 
is not sound range management. Continuous grazing 
was the primary oause range deterioration in the 
West, including Montana. 

3* Riparian areas may have to be fenoed to minimize 

livestock grazing but it is not necessary to eliminate 
rest-rotation grazing from the entire allotment. This 
issue addressed incorrectly in the DSIS and Hormay is 
quoted out of oontext. 

4. The National Bispn Range is used as an example of so- 
called "limited grazing" but is in fact an excellent 
example of rest-rotation grazing. The system has boen 
very suooessful in providing habitat for many game and 
non-game speoies of wildlife. 

3. Either in a supplement or an expanded final BIS 


n 


12 


wildlife, range, and reoreatlon objectives plus specifio 
methods for attaining them need to be more dearly de- 
tailed and laid out. 

6. A clearer dlsoussion of the ourrent and future status of 
hunting on the Refuge needs to bo 3et forth. At what 
wildlife population density, sex, or maturation will 
hunting be allowed? 

7. Either in a supplement or in an expanded final BIS 
more management alternatives should be explored and the 
preferred alternative should not pose the unnecessary 

confrontation between sound wildlife management and grazing 
by domestic llvestook. If outs in grazing, whioh may 
be neoeasary, are proposed, the should be proposed after 
other range management techniques suoh as read-rotation 
grazing have proven to be failures. 

In conclusion, the Montana .Wildlife Federation supports the 
Fish and Wildlife Servioe in its efforts to protect, preserve and 
enhance wildlife values of the CMR. howerer we cannot support any 
of the proposed alternatives in the OBIS. We oall on the Servioe 
to gather more preoise data and to exhaustively re-write this BIS. 
The Service should either issue a supplement or p lan on expanded 
final environmental impact statement. 


b 


Response to the Montana Wildlife Federation 


1. Please see Appendix lb for an expanded discussion of the planning 
process utilized for CMR. 

2. If PWS accepted a premise that livestock grazing and wildlife were 
incompatible, there would be no grazing on CMR. FWS believes that 
grazing under certain conditions, as to time, area, and intensity, 
is compatible with wildlife. 

3. The FWS believes that there is adequate discussion of both hunting 
and fishing in the DEIS. Hunting frameworks are established in 
coordination with Montana Department of Fish, Wildlife, and Parks, 
and in accordance with policies and legislation of the FWS. 

4. The economic analysis has been reevaluated, and the text revised 
according ly. 

5. All releases will be to either reintroduce a species not now pre- 
sent on the area or to bolster a lagging population; none of these 
will be penned. 

6. We agree that wildlife should cone first, and intend to manage CMR 
that way. Note that habitat management plans will be developed for 
each grazing allotment (or combination of similar allotments) to 
provide for the year-long requirements of wildlife. 

7. There 1 b no intention in the EIS to infer that an AUM taken from 
livestock will automatically be eaten by wildlife; the EIS deals 
with total wildlife habitat, not just forage produced. 

8. This Is beyond the level of detail for the CMR EIS. 

9. Two previous EIS's have discussed this issue: the Operation of the 
National Wildlife Refuge System, and the Mammalian Predator Damage 
Management for Livestock Protection in the Western D.S. 

10. The FWS will consider using any system that will meet wildlife 
objectives while minimizing permittee impacts. 

11. Hormay stated "that grazing would have to be eliminated if impor- 
tant riparian areas were not fenced ." If riparian areas were 
fenced, grazing could occur in the remainder of the allotment. 

12. The system designed at the National Bison Range was developed to 
enhance vegetation for bison. Thus, bison are the primary bene- 
factors. This is in accordance with the area's legislative man- 
dates. Conversely, Intensive systems presently in operation on CMR 
tend to primarily benefit livestock. This is not in accordance 
with the refuges enabling legislation. However, the FWS does not 
mean to Imply that specialized grazing systems will not be utilized 
in appropriate situations. 


13. The level of detail discussed herein is appropriate for this type 
of document, an EIS. 

14. This level of detail is beyond the scope of an EIS. Hunting frame- 
works are established in coordination with the Montana Department 
of Fish, Wildlife, and Parks, and in accordance with policies and 
legislation of the FWS. 

15. The FWS is currently studying rest-rotation; see also Response 010 
above. 


m 



Mr. Erwin W. Steucke, Area Manager 
Fish & Wildl ife Service 
Federal Building, Room 3035 
316 North 26th Street 
Billings, Montana 59101 


Dear Mr. Steucke, Re: C.M. Russell NWR DEIS 

After close consultation with our Montana chapters and extensive personal 
study of the issues our regional office would like to go on record as 
strongly supporting alternative B (the proposed action). Many nicty wonder 
why we chose this over alternative C, (Intensive Wildlife Management) or E 
(No Grazing) in lieu of the bad track record of grazing abuses and 
essentially it is because we feel that USF & WS can and will manage the 
refuge under B in such a way that wildlife, livestock, and recreational 
interests can each benefit from the specifics of the plan. 

We firmly believe that the prime objective of the Refuge is to promote, 
enhance, enrich, and in general care for its* wildlife. Proposal B, as 
presently defined, does in our opinion offer these opportunities while still 
allowing for livestock and recreational use. Conflicts should be weighted 
in most cases favoring wildlife however the recommended proposal should 
minimize most of these. 

Now for few specifics: 

1. The prime goal of the management plan should be to bring the lands 
back to prime productive capacity. This is especially important in 
the sensitive riparian zones. 

2. There must be better enforcement to stop overstocking, illegal live- 
stock trespass, etc. 

3. Predator management must be scientifically and carefully applied 
from a biological/ecological standpoint. 

4. I would encourage a greater peregrine release than 2 or 3 birds. We 
suggest 8-10 birds annually from 3 different hack sites. There now 

are sufficient eaptively raised birds to be ambitious as to numbers. I 
Also, a 65%-75% first year mortality of raptors mandates a larger 
numerical release. 


AMERICANS COMMITTED TO CONSERVATION 


5. A high priority should be placed on the establishment of a fenced, 
demonstration herd of bison similar to Custer State Park. This will 
greatly aid in increasing the public's appeal to the refuge and be 
an economic benefit to surrounding communities. 

6. Important wildlife inholdings should be acquired just as quickly as 
they become available. 

7. An 8-10 person, interdisciplinary advisory council, might be a 
worthy first step in launching the management plan. Obviously good 
and bad points can be made regarding advisory councils, but in 
general it could be the forim that keeps people talking instead of 
fighting. 

In summary, our Society feels the DEIS team and refuge have done a good 
conscientious job in putting together a working and workable plan. For too 
long apathy, overuse, misuse have charcterized the management options at the 
Refuge and these shortranged policies have not served any interest well. 

The opportunity to have a showcase refuge exists here and they should not be 
harmful to the local economy. We therefore reiterate our strong support to 
Alternative 

Sincei 



cert K. Turner 
Regional Representative 


Response to the National Audubon Society 


1. Any peregrine releases will be in conformance with the peregrine 
recovery team recommendations and the recovery plan. The DEIS 
states (page 10) that two introductions would be made. This could 
include as many birds as team recommendations and bird availability 
allows. At present, only two hacking sites have been identified. 
Others will be evaluated as time permits. 

2. In the planning process, a detailed discussion was held concerning 
this subject. The decision was made not to have demonstration 
bison herds on CMR in the Proposed Action because of increased 
fencing costs, surplus animal disposal problems, and Impacts on 
refuge activities. Bison herds in a natural setting are available 
for public viewing at Yellowstone Park, the National Bison Range in 
Montana, the Corps of Engineers' pasture in Fort Peck, Montana, 

Fort Niobrara National Wildlife Refuge in Nebraska, and in Custer 
State Park, South Dakota. 

3. The FWS agrees that the idea of an interdisciplinary advisory 
council has both good and bad points, and the establishment of such 
a council will be considered when planning implementation of the 
EIS . 


Mlm NATIONAL WILDLIFE FEDERATION 

1412 Sixteenth Street, N.W., Washington, D.C. 20036 202-797-6800 


December 5, 1980 


Mr. Erwin Steucke, Area Manager 
U.S. Fish and Wildlife Service 
Room 3035, Federal Building 
326 North 26th Avenue 
Billings, Montana 59101 

Dear Mr. Steucke: 

Enclosed are the National Wildlife Federation's comments 
on the draft Environmental Impact Statement on the Management 
of the Charles M. Russell National Wildlife Refuge. We 
appreciate the opportunity to comment, and hope that our 
recommendations will be of value to the Refuge planning team. 

If you have any questions regarding our comments, please 
contact Thomas Lustig (202, 797-6885) or myself (202, 797-6807). 
Would you please keep us informed of any further actions taken 
on the CMR management plan. Thank you. 

Sincerely, 

J. 

Cathy J. Bernstein 
Public Lands 


cc Wilbur Rehmann, Executive Director 
Montana Wildlife Federation 

Richard Day, President 
Montana Wildlife Federation 


45th ANNUAL MEETING — MARCH 27-29, 1981 Omni International Hotel Norfolk, Virginia 
100% reclaimed paper 


Comments of the National Wildlife Federation 
on the Draft Environmental Impact Statement 
on Management of the Charles M, Russell 
National Wildlife Refuge, U.S. Department of 
the Interior, Fish and Wildlife Service 

The National Wildlife Federation welcomes this opportunity 
to comment on the Draft Environmental Impact Statement C"DES") 
on the Management of the Charles M. Russell National Wildlife 
Refuge in Montana. 

The National Wildlife Federation ("NWF") with affiliates 
in all fifty states as well as Guam, Puerto Rico, and the Virgin 
Islands, and over 4 million members and supporters, is the 
largest nongovernmental conservation organization in the nation. 
NWF's Montana affiliate has approximately 1800 members, most of 
whom are hunters, fishermen, and/or wildlife observers. The 
Federation has a long history of active support for the improvement 
and preservation of wildlife habitat to optimize the size and 
diversity of wildlife populations. 

Introduction 

In recent years, the number of commercial and recreational 
users of the public lands has increased, placing a tremendous 
burden on the natural habitats to sustain their normal productivity, 
and threatening valuable natural resources. In the face of such 
resource conflicts, the Federation stresses the need to preserve 
representative areas of geological, biological, and ecological 
systems native to our country; and, to develop comprehensive 
habitat management programs which protect and enhance wildlife 
values. 

The Charles M. Russell National Wildlife Refuge ("CMR"1 
exemplifies this problem of resource conflicts on federal land. 


Over the years, three different agencies have had partial or 
total control over CMR management. Between 1936 and 1975 the 
Refuge was under joint management of the Bureau of Land 
Management ("BLM" ) and the Fish and Wildlife Service C"FWS" t. 

BLM took total control in 1975 through administrative action, 
but the following year Congress granted FWS exclusive 
jurisdiction over the Refuge. These administrative changes led 
to inconsistencies in the management of CMR and disregard for 
the initial purpose of this Refuge as set by President Roosevelt 
in 1936. 

At present, cattle graze freely over 50 percent of CMR 
Refuge while over 60 percent of the habitat is categorized as 
limiting to existing wildlife species. (DES, p. 39.) The Fish 
and Wildlife Service has proposed a management plan which would 
reduce grazing allotments and enhance wildlife resources, as 
well as "provide compatible human benefits associated with its 
wildlife and wildlands." CDES, p. 4.) 

The National Wildlife Federation strongly supports the 
goals and objectives for CMR which are listed in the alternatives 
section of the DES (pp. 4-6) as well as the specific wildlife 
objectives of the proposed alternative (p. 80) . These objectives 
satisfy NWF's policy for wildlife and rangeland management as 
well as complying with relevant federal laws (E.O. 7509, 


1/ Congressman Leggett (former Chairman of the House Subcommittee 
on Fisheries, Wildlife Conservation, and the Environment) , in 
congressional debates on H.R. 5512 (P.L. 94-223) stated; "... 

BLM has administered these lands in the past by encouraging 
multiple uses other than Fish and Wildlife. It has particularly 
emphasized commercial uses such as grazing. ... In contrast, 
the U.S. Fish and Wildlife Service's primary responsibilities both 
by law and in fact is to provide protection for wildlife and for 
wildlife habitat. . . . Consequently, there have been constant 
conflicts between the two agencies concerning how to manage these 
ranges (CMR Refuge, Kofa Game Range, Charles Sheldon Antelope Range). 
. . ." (16 U.S.C. 668dd, Feb. 27, 1976, p. 36597). 


Establishing the Fort Peck Game Range; P.L. 94-223, National 
Wildlife Refuge System Administration Act of 1966; P.L. 89-669, 
National Wildlife Refuge System - Designation — discussed in the 
following text) . The Federation agrees with FWS that wildlife 
conservation is the primary purpose of the Refuge, with livestock 
grazing allowed only when and to the extent compatible with this 
purpose. The CMR management plan has the opportunity to set a 
needed precedent for future management of wildlife refuges 
subject to pressure from commercial uses. 

CMR History 

Many of the conflicts involving past CMR management stemmed 
from differing interpretations of the Refuge's purpose. In 1936, 
President Roosevelt withdrew a 1.1 million-acre tract of Montana 
land from further settlement and designated this area as the 
Fort Peck Game Range (later changed to Charles M. Russell National 
Wildlife Range) to be managed "for the conservation and development 
of natural wildlife resources and for the protection and improvement 
of public grazing lands and natural forage resources." (E.O. 7509, 

1 Fed . Re£. 2149, Dec. 16, 1936). 

In his withdrawal. President Roosevelt provided: 

"that the natural forage resources therein 
shall be first utilized for the purpose of 
sustaining in a healthy condition a maximum 
of four hundred thousand (400,000) sharptail 
grouse, and one thousand five hundred (1,500) 
antelope, the primary species, and such 
nonpredatory secondary species in such numbers 
as may be necessary to maintain a balanced 
wildlife population . I I I Provided further, 
that all the forage resources within this 
range or preserve shall be available, except 
as herein otherwise provided with respect to 
wildlife , for domestic livestock. . . 7” 

(Emphasis added.) (Executive Order 7509, 

Dec. 11, 1936, 1 Fed. Re^. 2149, Dec. 16, 1936.) 


President Roosevelt's withdrawal made it clear that 
domestic livestock can graze on CMR only to the extent that 
they do not infringe upon the needs of wildlife, and that only 
forage not utilized by wildlife species should be available 
for livestock grazing. Roosevelt placed "the conservation and 
development of natural wildlife resources," as a primary reason 
for creating this Refuge and clearly expressed his concern 
that the Refuge be managed "to maintain a balanced wildlife 
population." (E.O. 7509). 

In the years following Roosevelt's Executive Order, 

CMR management began favoring livestock uses over wildlife. 

In 1975, Interior Secretary Morton transferred total management 
authority for CMR to BLM which led to even more intense 
grazing activity. Grazing during this time became a primary 
activity on CMR, with over 50 percent of the AUM's designatec 
for livestock grazing. As grazing increased, habitat for 
certain species of wildlife for which the Refuge was created 
deteriorated. (Congressional Record, Feb. 4, 1976, p. 2293; 
and Cong. Rec. , Nov. 14, 1975, p. 36598.) 

In an effort to reassert Roosevelt's initial goals for 
CMR, Congress transferred exclusive management authority for 
CMR to the Fish and Wildlife Service in 1976, under an amendment 
to the National Wildlife Refuge Administration Act. (P.L. 94-223, 
16 U.S.C. 668dd, Feb. 27, 1976.) Congress, in granting exclusive 
CMR management authority to an agency designated by Congress 
(P.L. 93-271; 16 U.S.C. 742b) as "the guardian of out Nation's 
fish and wildlife resources at the federal level" (Congressional 
Record, Feb. 4, 1976, p. 9.2203), acknowledged CMR's primary 
purpose as wildlife protection. 


276 


Habitat Deterioration Due to Grazing 

At present, over 60% of the Refuge is categorized as 
limiting to wildlife species. This condition exists in part 
because of livestock grazing, and in part because of the 
natural geologic and topographic conditions of CMR terrain. 

Over 50% of CMR consists of soil and landforms which 
are fragile and highly susceptible to runoff and erosion. 

Several thousand acres of panspots tsoils high in salt and low 
in water infiltration capacity) exist on the Refuge. These 
areas generally do not produce large crops of standing vegetation. 
The low humidity and strong winds characteristic of the area 
tend to draw water from the soil, which increases the problem 
of low water retention. 

The gradual increase in grazing AUM's over the years 
has placed an increased burden on the capacity of CMR soils to 
produce a healthy vegetative stock. Productivity rates, as 
stated, tend to be low on much of CMR terrain. As the cattle 
graze, they selectively remove palatable climax plant species, 
and in the process change the plant composition of the entire 
community. At present, only 51-75% of the plant species are 
representative of the normal climax community. Cattle, in 
grazing and trampling vegetation cn steep terrain and riparian 
areas, increase runoff and erosion significantly. This action 
negatively affects fisheries by increasing sedimentation of 
streams and reservoirs. 

At present, the habitat over most of CMR limits the 
nesting, foraging, and denning activities of existing wildlife 
species. The larger ungulates such as elk and bighorn sheep 
compete directly with cattle for forage. The cattle remove forb 
and grass species preferred by these ungulates. The wildlife 
species, overall, are limited by the lower plant species 


-7- 

The no action and multiple-use alternatives both place 
the protection of wildlife values on an equal or subordinate 
position to other uses such as grazing or recreation. Neither 
provides significant improvement of the presently deteriorated 
wildlife habitat, and both would require legislation changing 
the existing Congressional and executive policy that the 
primary purpose of CMR is for wildlife. 

The intensive management alternative would provide 
significant improvement in wildlife habitat, but is less 
economically feasible because substantial budget increases as 
well as changes in FWS policy would be necessary. Moreover, 

CMR grazing permittees would undergo greater economic hardship 
if the intensive management plan were fully implemented. 

FWS has also incorporated a plan for federal acquisition 
of all private and state inholding on the Refuge into the 
intensive management scheme. This action would not only be 
prohibitively expensive, but would also require changes in 
Montana State Land Board Policy. For these reasons, NWF does 
not favor the intensive management alternative. 

The Proposed Alternative 

The proposed alternative recommends a 33% reduction in 
grazing AUM's, in addition to a number of other habitat 
management techniques. FWS studies indicate that under the 
proposed management plan, overall habitat quality in the Refuge 
will improve between 16 and 105%, depending on the particular 
wildlife species evaluated. Proposed ratings for security cover, 
nesting sites, and forage for individual wildlife species show 
a general increase from the fair to good category. 

NWF supports these wildlife habitat improvements but 
recommends that FWS explore other alternatives which would achieve 


diversity resulting from overgrazing. Clearly, there is a 
need on CMR for a habitat management plan which provides for 
a reduction in the cattle's degradation of wildlife habitat. 

The conditions on CMR are typical of much of the 622 
million grazeable acres in the eleven western states. Over- 
grazing in the western states has been a major factor in 
rangeland deterioration for many years. The climax grassland 
communities which originally supported large herds of bison, 
antelope, and quail have been replaced by subclimax stages 
which inhibit the productivity of these wildlife species. 

FWS has the authority and legal obligation to reverse 
the deterioration on CMR. The National Wildlife Federation 
endorses the goals and effects expected from the DES proposed 
action (Table 13, at p. 80) as well as the FWS's effort to 
"preserve, restore, and manage in a generally natural setting a 
portion of the nationally significant Missouri River Breaks and 
associated ecosystem for optimum wildlife resources. . . ." 

(DES, p. 4.) 

DES Alternatives 

NWF used four criteria to evaluate the DES alternatives: 

(1) Does it satisfy the goals and objectives for CMR; (2) does 
it comply with existing law and FWS policy; (.3) is it economically 
feasible; and (4) does it minimize the economic hardship on 
livestock operations on CMR? 

Of the five alternatives discussed in the DES, only two 
fulfill the goals of CMR as mandated by Presidential and 
Congressional action: the proposed and the intensive management 

alternatives. 


- 8 - 

the same objectives yet minimize the adverse economic impacts 
on existing livestock operations. Our support of the proposed 
alternative is contingent upon FWS ' s demonstration that no 
other alternative will achieve its goals and objectives while 
mitigating economic losses to existing grazers. 

The Final Environmental Impact Statement (."FES") should 
evaluate certain alternatives to minimize disruption of existing 
grazing operations. For example, the option of utilizing a 
rest or deferred rotation system was mentioned in the DES, but 
not rigorously explore or evaluated. These rotation systems, 
as well as other alternatives which BLM and the Forest Service 
use to manage grazing on public lands, must be evaluated to see 
if they provide sufficient wildlife habitat improvement to meet 
FWS's goals and objectives. 

If, after careful scrutiny of less burdensome alternatives, 
FWS determines that the goals and effects of the DES proposed 
alternative can best be achieved by the 33% reduction in grazing 
allotments, then it should be adopted with whatever means are 
appropriate to mitigate any resulting economic impact. If 
there are no methods to mitigate losses to existing ranchers and 
still achieve the wildlife purposes for which CMR was established, 
then the commercial interests must yield to the primary goal of 
wildlife management. Nonetheless, the elimination of existing 
commercial uses should not be undertaken unless justifiably 
necessary for wildlife enhancement and protection. 

Additional Considerations 

The proposed alternative also recommends a combined 
program of soil ripping, shrub and tree planting, prescribed 
burning, and fencing. These techniques are all designed to 
increase the diversity and plant productivity of the Refuge. 

The Federation generally supports these wildlife enhancement 


277 


-9- 


-10- 

; measures, but requests that the FWS address the following points 


4) NWF stresses the need to preserve and enhance vital 


in the FES: 


waterfowl habitat. The reservoir provides habitat for osprey. 




cormorants, and great blue herons, while prairie falcons and 


1) Fencing is particularly useful in protecting riparian 



golden eagles nest in cliffs along the breaks. In the initial 


areas from cattle infiltration, improving spawning habit for 



habitat study, waterfowl on CMR received the lowest wildlife 


fish, securing nesting and feeding habitat for waterfowl, and 

2 


habitat ratings of any species or animal group on the Refuge. 

& 

decreasing stream sedimentation. NWF is concerned that fencing 



Vegetation, pond size, and nesting sites were all rated as poor. 


on CMR be designed so as not to impede the migration patterns of 



and therefore limiting to waterfowl. Although the management 


the large animals such as elk, antelope, and deer. 



plan focuses on the improvement of mammalian habitat, the FES 




should clearly outline its management plans to enhance avian 


2) Some soil types characteristic of CMR such as 


habitats, particularly for waterfowl. 


panspots and dense clay sites do not promote high plant 



productivity. The proposed soil ripping process can be very 


5) The DES is inconsistent in its discussion of 


effective in increasing the water retention capacity of the soil 


rangeland conditions. It states that CMR's range conditions on 


and thereby promoting plant productivity. However, in many 


74% of the grazing allotments are in good condition, and 18% in 


j cases ripping is only a temporary measure. The long term 


excellent condition. Range conditions for unallotted portions 


effectiveness of the soil ripping process depends on the 


of CMR are categorized as "predominantly excellent." These 


environmental factors which have created these panspots and dense 


statements are inconsistent with FWS's determination that over- 

9 

clay sites. FWS should explain the nature and causes of these 



grazing has caused sufficient deterioration in the condition 


panspots as well as evaluating alternatives to soil ripping. If 



of vegetation on the Refuge to warrant a 33% reduction in grazing 


soil ripping is the only possible alternative, FWS should ensure 

3 


allotments. FWS should clarify the discrepancy between these 


that there will be proper management of ripped areas so that 



statements. 


they will not regress to low productivity areas. 






Summary 

3) The DES is deficient in its discussion of nongame 




species. The introduction to the alternatives section states 



The National Wildlife Federation commends FWS on its 

that sharp-tailed grouse, mule deer, and pronghorn will be used 



efforts to protect, preserve, and enhance the wildlife values of 

as indicator species, and improvement in their habitats will mean 



CMR, but feels a more thorough exploration of management 

improvements for eighty percent or more of other resident species. 



alternatives is necessary. Although NWF supports the wildlife/ 

In discussing the alternatives, other game species Celk, white- 



recreational objectives of the proposed alternative, we urge that. 

tailed deer, upland birds) are often mentioned. However, the 



given the potential economic hardship which CMR livestock 

lack of discussion on nongame species suggests that the Refuge 



operators may undergo as a result of the proposed cut in allotments. 

will be managed primarily for game species. NWF emphasizes the 



FWS consider alternative management strategies in the FES which 

need for a balanced wildlife program which gives consideration 



satisfy its goals and objectives, while minimizing economic 

to all species; both game and nongame. 



hardship on livestock operators. 


Response to National Wildlife Federation 

1. 

Upon further study, FWS has concluded that it will not be necessary 
to acquire all private and state inholdings (see amended text). 

2. 

There are presently six rest-rotation and two deferred grazing 
systems in operation on CMR. FWS believes these systems to be less 
effective for wildlife abundance and diversity than light seasonal 
grazing with a favorable season of use. Furthermore, intensive 
systems are a much more expensive alternative and detract more from 
naturalness than the type of grazing generally suggested in the 
Proposed Action. Two of these will be monitored intensively in the 
future to determine the applicability of these systems to wildlife 
habitat management. 

3. 

All fencing on CMR will be in accordance with FWS standards for 
fences in wildlife areas. These standards were designed to provide 
for passage by wildlife to the extent possible. 

4. 

After reviewing public comment and reexamining pertinent research, 
the FWS has concluded that soil ripping is not a viable manipula- 
tive technique for habitat management on CMR. All references to 
ripping have been deleted from the Proposed Action. 

5. 

There is no intent to manage CMR primarily for game species. It 
became apparent by fulfilling the habitat requirements of sharp- 
tailed grouse and mule deer, the habitat requirements of many other 
wildlife species would be met. Improving habitat for these species 
on the many diverse vegetative sites provides for a diversity of 
wildlife and wildlife habitat. 

6. 

CMR contains little waterfowl habitat or areas with feasible 
development potential. Intensive and expensive development of 
waterfowl habitat in the UL Bend area of the refuge is proposed for 
the Intensive Wildlife Management alternative, but is not believed 
appropriate for the Proposed Action because of concerns for cost 
and naturalness. The Proposed Action should raise existing ponds 
suitable for waterfowl from their present condition to good condi- 
tion. Fort Peck Reservoir's value is providing habitat for molting 
and staging waterfowl. Few management options exist for enhancement 
of the reservoir. 

7. 

Range condition was not the sole criterion used in determining the 
level of grazing found in the Proposed Action. Soil stability, 
degree of slope, distance from water, residual cover requirements, 
etc., were used to determine the amount of forage excess to the 
needs of wildlife. Presently, there is not a direct correlation on 
CMR between good range condition and good wildlife habitat for most 
species. Alternative B in the text proposes to correct this 
situation. 


National 
Wildlife Refuge 
Association 



Dedicated to the 
preservation and 
perpetuation of the 
National Wildlife 
Refuge System. 


P.O. Box 124 

Winona, Minnesota 55987 

507/464-5940 

November 25, 1980 


Mr. Erwin W. Steucke, Jr., Area Manager 
U. S. Fish and Wildlife Service 
Room 3035, Federal Building 
316 North 26th Avenue 
Billings, MT 59101 

Dear Mr. Steucke: 

The National Wildlife Refuge Association Is a private, non-profit 
organization with a nationwide membership of people from all 
walks of life--people who have a common, fundamental concern for 
the preservation and perpetuation of our great National Wildlife 
Refuge System. 

The National Wildlife Refuge Association Is pleased to be able to 
comment on the Draft Environmental Impact Statement on the manage- 
ment of the Charles M. Russell National Wildlife Refuge. My 
comments reflect the opinions of Association members who have some 
knowledge of the management needs of the CMR Refuge, from both a 
professional and a user vantage. 

The National Wildlife Refuge Association supports the natural 
management concept. This will leave the refuge essentially as it 
Is now with no large scale water developments and no Interior 
fences . 

The National Wildlife Refuge Association strongly supports the 
overview statements on page 9, except for No. 3. These parameters 
will serve as logical guidance to many beneficial actions. 

The Association supports Alternative B (Proposed Action) but 
modified to include some of the elements found in Alternative C 
(Intensive Wildlife Management). 


For example, we cannot accept the statement that existing private 
cabins should remain. We suggest that they be phased out since 
such use Is not compatible with the primary purpose of the CMR. 
Continued use of the cabin sites would also appear to be In 
violation of Title 43, Section 21, and Title 50, Section 26.35, 
of the Code of Federal Regulations. Neither can we endorse shrub 
planting or soil ripping because of high costs, except where 
endangered species would benefit from such practices. We support 
boundary fencing only If it Is necessary to achieve habitat 
objectives that cannot be achieved In another manner. 


1 


We do not consider boat ramps and a well planned access road net- 
work to be Incompatible but an essential part of the refuge's 


I* 


278 


public use facilities. Correct management of the refuge's recrea- 
tion must Include primitive facilities to make use of the surplus 
game animals, fishing and outstanding scenery. Without such 
facilities the CMR wildlife populations and other resources will 
be poorly managed, with some areas overused and other large areas 
without visitation. 


The reintroduction of black-footed ferret, swift fox and peregrine 
falcon should receive very high priority. Also, the area's unique 
species such as bighorn sheep, burrowing owl, mountain plover and 
upland sandpiper should receive very high consideration In all 
planning and management actions, even to the disadvantage of mule 
deer and elk on small to moderate sized areas. 


We prefer the grazing scheme generally set forth in Alternative C. 
The draft EIS states that this type of grazing results in greater 
overall benefits to wildlife than Alternative 8. It is also more 
In keeping with the present U. S. Fish and Wildlife policy on 
grazing and agricultural practices on National Wildlife Refuges. 
This policy states: 

"Grazing, timber harvesting, and agricultural practices 
may be abusive and should be used only when necessary for 
proper management of wildlife resources , keeping in mind 
the desirability of maintaining natural ecosystems." 


The draft EIS only peripherally discusses seasons of use for live- 
stock. In the context of habitat improvement or manipulation, 
"season of use" will have as big an inpact on habitat as the AUMs 
utilized by livestock. We therefore recommend that "turn-in" 
dates io refuge pastures should not be before June 15 on season- 
long pastures or May 15 on units with rotation grazing systems, 
unless earlier dates are needed for habitat manipulation. 


4 


An in-depth analysis of predator control is also avoided by the 
draft EIS. The proposals on predator control also seem to conflict 
with FWS policies concerning predator control on refuges, which 
states: 

"Use of pesticides and animal control should be last 
resorts, employed when no feasible alternatives exist, 
used only when necessary for proper management of wild- 
life, and keeping in mind the desirability of maintain- 
ing balanced ecosystems. These practices are generally 
Inimical to wildlife conservation, and their use should 
require special justification ." 


On March 29, 1979, Assistant Secretary Robert Herbst further 
elaborated that: 


"Animal control will be undertaken to assure balanced 
populations consistent with the optimum management of 
refuge habitat. In no instance should control programs 
be based solely upon a need to alleviate damage to 
economic users (such as farmers and grazers)." 

At least one of the two viable alternatives (Alternative B or C) 
in the draft EIS should reflect the current FWS policies 
regarding predator management on the CMR Refuge. 


The various archaeological and historic sites found on CMR should 
be retained In their present form without any additional manage - 
ment or expenditures of funds diverted from wildlife. In no case 
shou 1 d wildlife funds be used for the management of these 
structures. 


The Association does not endorse Alternative A (No Action) because 
there is a need to improve ranqe conditions from their present 
low levels. The Fish and Wildlife Service should strive to 
improve range conditions for the benefit of wildlife and other 
compatible uses. 

The Association does not endorse Alternative D (Multiple Uie) 
because National Wildlife Refuges are not multiple use areas. 

They are established primarily for wildlife. Only through an act 
of Congress could CMR be removed from the refuge system and made 
a multiple use area. 

Alternative E (No Grazing) is not endorsed by the Association 
because properly regulated grazing provides a useful wildlife 
management tool. In addition, we do not believe it desirable to 
change or revoke Executive Order No. 7509. 

In sunmary, the National Wildlife Refuge Association endorses 
Alternative B, with the modifications enumerated above. We con- 
gratulate the Fish and Wildlife Service for its efforts in com- 
piling this concise and detailed Draft Environmental Impact State- 
ment. We are grateful for the opportunity to submit this 
written statement. 


Sincerely, 




~z£z~ 


Forrest A. Carjieifter 
President 

National Wildlife Refuge Association 


Response to the National Wildlife Refuge Association 


1. Please see responses to Defenders of Wildlife. 

2. Recreation facilities are Included in all alternatives. 

3. See response 01 above. 

4. The FWS concurs with your recommendation. 

5. The FWS will conform to its own policies on predator management. 

This subject has been addressed in two previous EIS's: Operation 

of the National Wildlife Refuge System, and Mammalian Predator 
Damage Management for Livestock Protection in the Western U.S. 

6. The FWS is in agreement. Wildlife monies will not be used for the 
management of archeological and/or historic sites on CMR. 



RICHARD H. pough, President November 3, 1980 


Mr. Erwin W. Steucke, Area Manager 
U.S. Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

Dear Mr. Steucke: 

I appreciate receiving the draft environmental impact statement relative to the 
"Management of Charles M. Russell National Wildlife Refuge." It is certainly an 
impressive and, I would assume, very useful document. 

May I, without going into great detail, make some general comments. In the light I 
of the facts brought out in the enclosed paper, "Grazing and Haying Effects on I 

Habitats of Upland Nesting Birds," by Kirsch, Duebbert and Kruse of your own II 

Service, I wonder whether the refuge can be regarded as having any "excess forage" I 
when viewed in the terms of wildlife's needs. 


If there were no livestock on the refuge, it seems to me no predators, coyotes, 
etc., would need to be controlled. Any excess that tended to spill over into 
adjacent lands could certainly be taken care of by any of the ranching neighbors 
who feel the need to do so — although a great many of them tell me they have 
nothing against the coyote. 


\ 


I might also comment on the prairie dogs. Not only should they be encouraged in 
the interest of the black-footed ferret but also because the dog-town areas are 
important to the mountain plover as nesting areas. 


I* 


If Executive Order 7509 needs to be changed, why not take stops to do so? It 
seems to me there is nothing sacred about it. Virtually the whole West is grazed 
by livestock. Why not have a few areas that aren't and let them return to, as 
nearly as possible, the condition they were in before the white man came to 
America with his livestock? 


Sincerely yours, 
Richard H. Pough 


Enclosure 

ADVISORS ON LAND PRC8ERV AT I O N / COUNSELORS ON IMAGINATIVE PHILANTHROPY 


279 


Response to Natural Area Council 


1. The FWS believes the type and amount of livestock grazing suggested 
In the Proposed Action will achieve the wildlife and habitat objec- 
tives found on page 5 of the text. Objective 4 on this page will 
be monitored closely to determine if the level of grazing proposed 
is appropriate. 

2. The predator problem has generally been related to livestock losses 
off the refuge. 

3. The FWS recognizes the value of prairie doge and their towns in 
wildlife management. 


Natural Resources Defense Council, Inc. 

85 KEARNY STREET 
SAN FRANCISCO, CALIFORNIA 94 I 08 
4*5 4 * *“65®* 

Washington Office 

. 7*5 « street. N.w. January 13, 1981 

SUITE 600 

WASHINGTON, D.C. 10006 
SOI sss-Saio 

Erwin W. Steucke, Area Manager 
United States Fish & Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

re: Draft Environmental Impact Statement/ 

Management of Charles M. Russell 
National Wildlife Refuge 

Dear Mr. Steucke: 

1 have reviewed the above-captioned document and wish to 
submit the following comments on its contents on behalf of the 
Natural Resources Defense Council, Inc. (NRDC) , a non-profit, 
environmental membership organization. I appreciate your interest 
in receiving our written comments despite closure of the formal 
comment period. 

NRDC has long been concerned about the management of live- 
stock grazing on publicly-owned lands within and outside national 
wildlife refuges. We have been particularly concerned about 
grazing management on the Charles M. Russell National Wildlife 
Refuge (CMR) , because of its spectacular resources. Indeed, 
as you may already know, evidence detailing the adverse impacts 
of the Bureau of Land Management's administration of grazing on 
the CMR' s resources was submitted by us in connection with the 
lawsuit that led to the preparation of this draft Environmental 
Impact Statement (EIS), NRDC, et al v. Morton, et al . , 388 F. Supp. 
829 (D.D.C. 1974). We believed then, and still believe, that the 
EIS process would provide the Fish & Wildlife Service (FWS) with 
both the opportunity and the information needed to develop a 
management plan which would be tailored to its unique wildlife 
resources. 


100% Recycled Piper 


Nra York Office 
lit EAST 4 SND STREET 
NEW YORE, N.Y. lOOfJ 
sis 949-0049 


Erwin W. Steucke, Fish & Wildlife Service January 13, 1981 

The draft EIS substantiates our concerns. Clearly, livestock 
grazing has had, and is having,- significant adverse effects on 
the wildlife of the CMR and is preventing the Refuge from fulfilling 
the objectives for which it was established. Equally clearly, 
changes in current management practices, including reductions in 
livestock numbers, are badly needed to fulfill those objectives 
as well as the FWS's policy regarding livestock use of refuges. 

While the proposed action recognizes this need for change, 

neither it nor the draft statement live up to our expectations for the 

the following reasons. 

The draft's most serious flaw stems from its failure to comply 
with NEPA’s most important objective -- the consideration of properly 
selected alternatives. See , e.g. , Council on Environmental Quality, 
Regulations for Implementing the Procedural Provisions of the 
Procedural Provisions of the National Environmental Policy Act, 

SS 1502.14. 

The draft purports to consider four "alternatives" in addition 
to the Service's proposed action. Two of the four, the no action 
alternative and the multiple use alternative, admittedly "do 
not provide a wildlife refuge situation." P. 26. According to 
the draft, the Service lacks the authority to implement the no 
grazing alternative.* The remaining alternative, the intensive 
wildlife management alternative, is not only extremely expensive, 
but would also violate CMR' s stated mission, by "destroy [ing] the 
naturalness of the Refuge." Id . 

Thus, the draft considers only one viable alternative — 
the proposed action. Obviously, consideration of a single such 
alternative does not comply with the requirements of NEPA or the 
CEQ Regulations. Equally obviously, the proposed action is not 
the only viable alternative for management of grazing on the CMR. 
Accordingly, we specifically request the consideration of at least 


I believe that the Service does, in fact have the authority to 
eliminate grazing on the CMR. Nonetheless, this alternative would 
be extremely difficult and expensive to implement. 


3 


Erwin W. Steucke, Fish 6 Wildlife Service January 13, 1981 


one additional alternative in the final EIS which involves use of 
carefully designed prescriptive grazing to achieve or maintain 
desired wildlife habitat conditions. This alternative should not 
involve either the unrealistic acquisition plan or the other 
management practices that make alternative C unacceptable. In 
addition, it should directly address the existing conflicts 
between livestock and wildlife use of key areas, including, in 
particular, riparian areas. 


The draft EIS acknowledges the importance of riparian areas 
to CMR' s wildlife. See , e.g. , p. viii. It also reveals that the* 
are currently considered "sacrifice areas" as the result of 
cattle concentrations. P. 16. Notwithstanding the proposed 33% 
reduction in livestock use, it is not at all clear that the 
proposed management will adequately protect these areas and 
achieve optimum wildlife conditions. In part, this is the result 
of the draft's failure to explain how the proposed level of use 
was determined. It is also the result of its failure to provide 
at least habitat-specific descriptions of the management actions 
contemplated by the proposed action as well as to analyze the 
impacts of the proposed action and "alternatives" in such terms. 

As far as other elements of the Service's plan are concerned, 
we support the re introduction of endangered species in the Refuge, 
the minimization of so-called range "improvements," and the phasing- 
out of farming especially along the Missouri River bottoms. We 
are opposed, however, to predator control practices except where 
necessary to protect endangered species as well as to the pro- 
posal to "rip" as many as 10,000 acres of CMR to improve vegetative 
productivity. The proposed action regarding predator control is 
inconsistent with FWS policy while the proposed ripping conflict* 
with the stated mission of CMR. 

In conclusion, we appreciate the opportunity to submit these 
comments. We hope that the final EIS will remedy the problems 


R 


I 


4 

Edwin W. Steucke, Fish & Wildlife Service January 13, 1981 

we have identified as well as that the management plan ultimately 
selected for the CMR will fulfill its mission and the mission of 
the FWS. 

Sincerely, 

\)o(kumui_ 

Johanna H. Wald 

JHW: as 

cc: Bill Knaur, Federal Center, Denver, Colo. 


Response to Natural Resources Defense Council, Inc. 


1. The FWS considered five alternatives including some not within the 
its augumentation authority (as per CEQ regulations). The EIS 
refers to using livestock as a management tool in several places, 
and in fact is actually the main idea in the Proposed Action. 

Also, please see amended text on pages 18 and 25 for changes that 
more accurately describe needs for the Intensive Wildlife Manage- 
ment alternative. 

2. CMR wildlife habitat was evaluated on a section-by-section basis 
and actions prescribed for each. 

The amount of forage available to livestock was computed on a 
sectlon-by-section basis. Since there are over 1,000 sections on 
CMR, a listing of the tabulation of each is beyond the scope of 
this document. The 32.6 percent reduction is an average of the 
reductions applied to the sections. See also new Appendices lb, 2, 
and revised Appendix 15. 

3. Please see responses to Defenders of Wildlife comments. 


Public Lands Council 

Suite 1020 

425-131h Street, N W 
Washington, D C 20004 
(202) 347-5355 

National Cattlemen's Association National Wool Growers Association 

P O. Box 569 
(1001 Lincoln Street) 

Denver. Colorado 80201 
(303) 861-1904 

December 5, 1980 


600 Crandall Building 
Salt Lake City, Utah 84101 
Phone (801) 363-4483 


Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

Dear Mr . Steucke : 

This is to present the comments of the above national organi- 
zations on the draft environmental impact statement for the C.M. 

Russell National Wildlife Refuge. 

We agree with the critical comments and review of this EIS 
submitted to you by Mr. C.E. Hitch on behalf of the Montana Public 
Lands Council. 

Like the Montana Public Lands Council, we found the draft EIS 
so confusing, indefinite and contradictory that it is difficult to 
analyze it. As a matter of fact, we believe the draft is so inade- 
quate that a revised draft should be prepared and circulated (as 
provided in § 1502.9 of the CEO regulations on implemer. _ing the 
procedural provisions of NEPA) so as to provide a meaningful oppor- 
tunity for public comments. 

The present document appears designed to obscure the signifi- 
cant issues involved in the proposed action and alternatives and to 
discourage specific public comment. How can the public comment on ^ 
something so lacking in relevant information and so lacking in 
identification of goals, choices, and impacts? 

Although FWS claims that scoping was done, we fail to see the 
results in this document, explicitly or implicitly. We are not 
sure whether it is an EIS on livestock grazing management, wildlife 
management, or both. At any rate, it fails in every way to present 
the reasonable alternatives and adequate information that the CEQ 
regulations indicate is necessary to evaluate the choices and trade- 
offs that might be involved. 


The alternatives presented in the EIS do not cover an adequate 
range of management actions nor is there sufficient information 
presented regarding each alternative so as to be able to understand 
fully their impacts. 


There is practically no information given on how each alterna- 
tive would affect wildlife. Most of the alternatives would "improve 
wildlife habitat" we are told and asked to accept on faith alone. 

Little evidence is presented on how and how much wildlife populations 
or other related values would be affected by the actions in the al- 
ternative programs. Practically no figures are given on present 
wildlife populations or on expected numbers under the alternatives. 

While Executive Order 7509 appears to have withdrawn the area 
for wildlife numbers and "for the protection and improvement of pub- 
lic grazing lands and natural forage resources", the FWS does not 
appear willing to operate the area for these purposes. The EIS says, 
in effect, that wild animal populations or densities are not important, 
it is habitat quality and quantity that is important whether or not 
that is helpful to wildlife quantity or quality (or injurious to 
livestock grazing) . 


On pages 4, 5, and 6, prior to any discussion of the alternatives, 
there is presented a listing of CMR goals and objectives. Apparently 
these objectives are non-debatable as far as FWS is concerned. There 
is no discussion of these objectives and no EIS was prepared on them 
or will be prepared on them. They are used only to "prove" that al- 
ternatives other than the proposed action are not possible or desir- 
able, according to FWS. To make it even more difficult to evaluate 
them, the goals and objectives are not quantified or gualified. 

Also making it impossible to evaluate just what it is that each 
alternative purports to do or accomplish are the statements in each 
alternative description that the Service will develop in the future 
habitat management plans that will have unidentified affects on graz- 
ing and wildlife. In other words, the EIS not only does not tell the 
public exactly what the Service has in mind at present under each 
alternative, it hasn't yet decided what it will do. Or perhaps it is 
just reserving the right to do whatever it feels like in the future 
no matter what alternative is selected. 

If we don't know yet what the proposed programs are under each 
alternative, just what is it that we are examining in this EIS? 


The whole document appears to us to be a rationalization of a 
decision or decisions already made, in violation of the CEQ regulations. 
An EIS is supposed to be prepared before major decisions are made or 
conclusions drawn. An EIS is supposed to help improve the decision- 
making process. It should identify the benefits and impacts, in kind 
and size, and give the public an opportunity to comment on pertinent 
issues. The CMR EIS meets none of these requirements. 

The EIS obviously prejudges livestock grazing from the start. 

The document reveals an abysmal lack of understanding or knowledge of 


281 


livestock grazing or range science issues. Perhaps this is because 
there appears to have been little input from anyone other than wild- 
life specialists. (The list of preparers on page 104 fails to reveal 
each individual's experience and qualifications as required by the 
CEQ regulations. 


I* 


Examples of the ignorance of livestock and range issues appear 
in the discussion of economics in Appendix 13: Private rates for 

grazing are $10 to $20 per AUM in the area and since the CMR permit- 
tees pay only $1.89 per AUM they are getting "substantial federal 
subsidies." Anyone who had even a modicum of understanding of the 
public land grazing fee formula would not make such a stupid state- 
ment. (For your enlightment, the formula is based on private lease 
rates and the higher costs of operating on public land.) The error 
is compounded when $1.89 per AUM is used as the direct benefit value. 

We believe that this proves that FWS is incapable of analyzing live- 
stock issues and at least that part of the EIS should be given to 
another Federal agency or to a range science group outside the govern- 
ment that has some expertise in livestock grazing and range matters. 


5 


Four of the five alternatives involve cuts in livestock grazing. 
The fifth, the "no action" alternative, involves a continuation of the 
status quo (no livestock grazing increase) . The multiple use alter- 
natives is misnamed. At one point, it is described as an action 
involving an initial cut and a gradual increase to a level slightly 
below present grazing numbers; on some other pages the high point is 
described as a few AUMs above present numbers. There is also a variety 
of figures given on the amounts of the livestock reductions in other 
alternatives . 


It is apparently accepted as a premia that livestock grazing and 
wildlife are incompatible. Since this is such a central issue it 
should have been more adequately covered in the document. 

The literature review in Appendix 16 attempts to substantiate the 
above bias by citing out-of-context selections from wildlife writers. 
Dr. R.J. Mackie is quoted extensively in this appendix and throughout 
the rest of the document in words that imply that he believes live- 
stock and wildlife are always in conflict. However, that same Dr. 
Mackie is cited as indicating that information is lacking with respect 
to impacts of grazing on wild ungulates. We understand that Dr. Mackie 
has recently stated that existing studies have not produced substantive 
evidence for the existence of livestock/wildlife competition generally, 
nor more than very general conclusions about the exact nature and 
importance of such competition. 

Appendix 16 also reveals that those cited are saying that there 
may be diet and other competition between wildlife and livestock in 
"overgrazed" situations — not all situations! But the EIS reveals that 
85 to 95% of the range in the CMR Refuge is in "good" or ’fexcellent" 
condition 1 

It is obvious that the severe grazing reductions in the Proposed 
Action are not directed at "overgrazed" conditions. As a matter of 
fact, a comparison between the proposed cuts and the range condition 
allotments by allotment indicate that there would be severe reductions 
in areas in which all the land is in good or excellent condition. 


This study shows there is no correlation between allotment range 
conditions and proposed grazing reductions in the Proposed Action. 


We also found no information in the document on range trend nor 
any substantiation of the assertion that the Proposed Action would 
increase the amount of land in "excellent" range condition. We 
recognize that the EIS makes a differentiation in a couple of places 
between range condition and habitat condition. "Poor" range condi- 
tion is best for prairie dogs, it indicates. But it is impossible 
to track just how and how much FWS is going to decrease range condi- 
tions under the Proposed Action in order to increase habitat condi- 
tions ! 


7 


In summary, for the reasons mentioned in this letter and in the 
letter from the Montana Public Lands Council, we believe that it is 
imperative that the draft statement be discarded and a more intelli- 
gible draft statement be prepared. 

Sincerely, 

Ronald A. Michieli 

Director, Government Affairs 

For Land and Natural Resources; 

NCA Executive Director, Public 
RAM/mes Lands Council 


Response to Public Lands Council, National Cattlemen's Association, 
and National Woolgrower's Association 


1. As stated in the Foreword, "This Environnental Impact Statement 
follows the Council of Environmental Quality guidelines for National 
Environnental Policy Act docunents as amended July 30, 1979." The 
EPA rated this docixnent as LO-1 (Lack of Objection - sufficient 
information); therefore, FWS believes the document is adequate. 

Scoping was completed as outlined in the last paragraph on page 1. 

. The Multiple Use alternative was a direct result of the scoping 
process, i.e., many persons expressed a desire to have the refuge 
under the multiple use concept. 

Wildlife management and livestock grazing on CMR are Inseparable. 
Thus, the EIS covers both aspects. 

2. The EIS purposefully does not address population nuabera but wild- 
life habitat (see page i. Foreword, paragraph 4). The effects of 
the five alternative actions on wildlife habitat are discussed in 
the Wildlife Habitat-Range Resources section of the consequences of 
each alternative. Wildlife populations are modified by actions of 
man as well as nature. 

Executive Order 7509 established CMR for "the conservation and 
development of natural wildlife resources and for the protection 
and Improvement of public grazing lands and natural forage res- 
ources." The Executive Order further establishes two priority 
wildlife species and that forage surplus to the needs of wildlife 
be available for domestic livestock. The EIS recognizes habitat as 
the key to wildlife abundance (nimbers) . 

3. According to CEQ Guidelines (Sec. 1502.1 Regulations for Implement- 
ing the provisions of the National Envlrormental Policy Act), the 
purpose of an EIS is to discuss the Impacts on the environment of 
various alternatives and methods of reaching or attaining certain 
goals and objectives; not a discussion of the rationale supporting 
those goals and objectives. Such rationale comes from legislation 
and Service policy and is contained in program management documents 
on file in the FWS Lewistown office. 

The goals and objectives were developed early in the planning 
process and presented at the public meetings for comment and 
revision. The level of detail requested here is beyond that 
appropriate for an EIS. 

4. Although most of the refuge staff have wildlife degrees rather than 
range, they also have almost 110 years of grassland management 
experience with federal land management agencies. In addition, two 
staff members have degrees in range management. 


5. Your concern over the $1.89 on AUM is correct in that the $1.89 fee 
does not reflect the value of the AUM to the ranch operation. This 
has been corrected by adopting a linear programming (LP) approach 
to estimating the financial impacts to the rancher. 

The LP analysis estimates the change in gross income associated 
with a change in CMR AUMs. The LP measures changes in rancher cash 
expenditures, labor Inputs, returns to investment, and beef cow 
inventories. The analysis does this using an average ranch budget 
for ranches of different ranch size classes. These budgets take 
into account numerous factors including seasons of use and differ- 
ences in dependencies. This approach tailors the analysis to the 
regions and ranches by reviewing the ranch budgets with a repre- 
sentative rancher panel for EIS area. In this case the value per 
AUM was $12.87. 

This technique is being applied to analyze similar grazing actions 
for BLM. The National Cattlemen's Association and Public Lands 
Council support this approach to impact assessment. See Appendix 
10 for example Inputs and outputs. The subsidy results not from a 
flow of federal funds ($106,830 out and $15,133 back), but from a 
resource subsidy to ranchers who receive a AUMs worth substantially 
more than $1.89 to them for $1.89. It is this difference that 
generates the subsidy. 

6. If FWS accepted a premise that livestock grazing and wildlife were 
incompatible, there would be no grazing on CMR. FWS believes that 
grazing under certain conditions, as to time, area, and intensity, 
is compatible with wildlife. Thus, FWS believes the issue is 
covered adequately in the document. 

7. FWS would like to point out that range condition and wildlife habi- 
tat condition are not the same. See Foreword. 


292 



Erwin W. Steucke, Area Manager 
U.S. Fish and Wildlife Service 
Federal Building, Room 3035 
316 N. 26th St. 

Billings, Mont. 59101 

Dear Erwin W. Steucke, 


Sierra Club 

Northern Great Plains Region 


Bruce Hamilton 
Regional Representative 
P.O. Box 1078 
Lander, Wyo. 82520 
(307) 332-9824 

Dec. 2, 1980 


Rose McCullough 
Assistant Representative 
715 South 14 St. 

Lincoln, Neb. 68508 
(402) 435-7023 


Thank you for keeping me Informed about planning for the Charles M. Russell National 
Wildlife Refuge. The CMR is one of the most spectacular and controversial refuges in the 
system. Unfortunately, political considerations, rather than ecological considerations, are 
all too often the basis for management. You and your staff are to be comnended on the recent 
draft environmental impact statement because It tries to steer clear of the adverse local 
political climate and tries to chart a course that Is right for the wildlife resources that 
are entrusted to you as guardian of the CMR. 

Future management directions should not be bound by past mistakes. The DES outlines the 
problems with existing management and the consequences of no action quite clearly (pp. 62-68). 
If this is an accurate representation of the situation It Is obviously unacceptable and 
reform is needed. It's amazing that stocking rates are still set on the basis of a 1952-53 
range survey. 

Overall, I think you have chosen a prudent course in alternative B, the proposed action. 
However, I should limit niy endorsement by adding that there are parts of the proposed action 
that I disagree with or am uncertain about because too little information is provided. I 
should also add that the proposed action looks the best because all the other alternatives 
aren't really available choices or are unacceptable. A more realistic range of alternatives 
would have made a choice harder, but more meaningful. 

As stated earlier, the no action alternative has led to a steady degradation of key parts 
of the CMR. (It should have been pointed out that present management has not been detrimental 
to most of the CMR and that the conflicts that deserve inmediate attention are limited to a 
small, but highly critical segment of the entire refuge.) In your own words (p. 26) the no 
action and multiple use alternatives "do not provide a wildlife refuge situation." Also the 
multiple use option is not allowable under existing law. Similarly, the no grazing alternative 
Is not possible under existing executive order. The intensive wildlife management alternative 
is too costly to Implement and, by your own admission would "destroy the naturalness of the 
refuge" (p. 26)--a result that violates the stated mission of the CMR. In sumnary, there are 
no serious options to choose from. All the alternatives are straw men. I would have preferred 
to see a series of variations of the proposed action with different realistic mixes of live- 
stock curtailment, range Improvements, land treatment, inholding acquisition and wildlife 
species reintroduction. Instead, by endorsing the proposed action we end up giving you a 
blank check on some fairly significant decisions. 

For example, obviously a change in livestock management practices is warranted and 
probably a significant cut in livestock use is necessary. But where did the magic number 33% 


"Not blind opposition to progress, but opposition to blind progress." 


2 

come from? It's impossible to follow the extrapolation from the summary of Mackle's work 
in appendix 15 to the conclusion that a 33% cut is warranted. 

I'm also concerned that the livestock reduction may not translate into an improved on- 
the-ground situation at CMR. Most of the critical conflicts occur in riparian zones that are 
scarce and heavily used by both livestock and wildlife. Will a 33% reduction in stocking 
levels reduce this conflict? Or will the remaining cattle continue to congregate in the 
riparian areas? 


It seems to me that site specific grazing management programs would be useful, and would 
also be more in keeping with the requirements of the NRDC court case. You state (p. 10) that 
plans for each allotment will be prepared by 1985. Perhaps I'm just too impatient. Under 
each alternative I'm told how much additional fencing, ripping, water development, etc. to 
expect. But I'm never told where to expect it. Will you be fencing riparian zones? Will 
there be an attempt to develop water on dry low-slope areas to disperse livestock use? Is 
the ripping a one-time-only treatment to restore a trampled, eroded area or is the ripping a 
periodic intensive management treatment? Are you trying to build up big game herds to a point 
where additional livestock cuts will be necessary in the future? Does establishment of set 
grazing rotation systems preclude the use of prescription grazing to accomplish short-term 
vegetation manipulation? 


I'd also like to comment on a few specific proposals: 


Endangered species reintroduction : I'm generally very pleased with your announced program. 

Ooes aval l ability limit the number of peregrine reintroductions to two? 

Bison : Under alternative C you suggest bison reintroduction in U.L. Bend. Why wasn't 

bison reintroduction explored in more areas and considered part of the proposed action? 

Bighorn sheep : I'm concerned about plans to introduce more sheep when you aren't sure 

why the last population crash occurred. 

Predator control : On a wildlife refuge I would hope predator control is only carried 

out in extreme situations, such as when endangered species are threatened. Wildlife refuges 
are established for all native wildlife— not just game species. With this in mind I would 
strongly oppose proposals to control coyotes to "protect" big game species. 

Farming : Most farming should be phased out. While row crops may help some exotic species 
like pheasants they take native habitat from native game birds. Some minimal farming around 
the edges of the CMR to minimize wildlife conflicts on surrounding cropland may be justified-- 
if it can be demonstrated that this technique works. Farming in riparian zones should be 
phased out—especially along the Missouri River bottoms. 

Ripping : I fail to see how ripping makes sense If you are trying to maintain the natural 

setting. One time ripping of severely abused areas may be justified. But ripping to "improve 
wildlife habitat and reduce soil erosion" (p. 20) at the same time you are phasing out farming 
seems at cross purposes. Especially in times of agency budget cutting, minimal manipulation 
should be the rule. 


Pool level ranagement : Does the FWS work with the Corps of Engineers to try to make sure 

the pool level of Fort Peck Reservoir is managed in a manner that does not harm fish and 

wildlife? Should this be part of the refuge master plan? Are there other COE plans that 

could conflict with FWS plans where management direction Is needed? Would major Industrial 
water marketing from Fort Peck Reservoir for coal development severely Impact CMR? If so, 
can steps be taken to minimize the damage? 


3 

Roads : There is some discussion in the appendices about the adverse impact of roads on fi y 

big game and other wildlife. Shouldn't a travel plan/road closure policy be part of this plan?! " 

Air quality : In the "affected environment" section (pp. 31-36) there is no discussion fl 
of present air quality, future threats to that quality, and measures available to protect 
present quality. 

Fires : In the DES there are general statements about how much land might be subject to 

prescribed burning. I would prefer to see a fire management plan where the refuge is zoned ^ 

into areas where wildfires will be allowed to burn, areas where prescribed burning will be ™ 

pursued, and areas where immediate fire suppression will be necessary. 

Mineral development : The CMR has marginal deposits of oil, gas, aggregate, bentonite | 

and coal (p. 36). who owns the mineral? Is any of it withdrawn? How will the FWS deal with IfQ 
development proposals if any surface? Why wasn't this addressed in the DES? 

Thank you for the opportunity to conment. Please send me a copy of the final EIS and 
any other news about the CMR. 


Sincerely, 


Bruce Hamilton 
Regional representative 


Response to the Sierra Club, Northern Great Plains Region 


1. The amount of forage available to livestock was computed on a 
section-by-section basis. Since there are over 1,000 sections on 
CMP., a listing of the tabulation of each is beyond the scope of 
this document. The 32.6 percent reduction is an average of the 
reductions applied to these sections. See new Appendices lb, 2, 
and revised Appendix 15. 

2. The Proposed Action will exclude livestock from over 90 percent of 
the riparian habitat along the Missouri and Musselshell Rivers 
within the refuge. Much riparian habitat will receive little or no 
livestock grazing. Other riparian areas will still have light to 
moderate livestock use, but seasons of use will be favorable for 
some recovery. Livestock grazing in all habitats on the refuge 
will be governed by the wildlife objectives on page 5 of the text. 
If the proposed level and type of grazing do not allow these ob- 
jectives to be achieved, grazing will be modified. 

3. See response #2 above. Also, the exact locations of some of the 
developments are beyond the scope of the EIS. After reevaluation 
of data and comments, ripping has been deleted from the Proposed 
Action and the text revised. Development of additional water on 
the refuge would be detrimental to most wildlife in that it would 
distribute livestock into areas now used almost exclusively and 
needed by wildlife. It is not the intent of the FWS to increase 
big game populations beyond the levels proposed in the wildlife 
objectives. The FWS believes the level of grazing set forth in the 
Proposed Action is compatible with these objectives. While rest 
rotation grazing systems would not preclude the use of prescription 
grazing for short-term habitat manipulation, it reduces the via- 
bility of such an option. 

4. In the planning process, a detailed discussion was held concerning 
this subject. The decision was made not to reintroduce bison onto 
CMR (including UL Bend) because of increased fencing costs, surplus 
animal disposal problems, and impacts on refuge activities. The 
FWS will, however, work with any permittee desiring to replace 
cattle with bison. 

5. See response #3 above. 

6. A Memorandum of Agreement (Appendix 3) between the COE and FWS 
recognizes the primary use of CMR as a wildlife area and provides a 
vehicle for ensuring that the mandates of both agencies are met. 

The FWS, Montana Department of Fish, Wildlife, and Parks, and COE 
will work together to ensure the best possible fishery management 
within the constraints of primary mandates of the COE. Industrial 
water marketing is speculative at this time and beyond the scope of 
the EIS. 


283 


7. Several hundred miles of designated roads exist on the refuge. 

Those suitable for continued use will remain open, while those 
susceptible to landslides, washouts, and wildlife conflicts may be 
abandoned or changed. The travel map is beyond the scope of the 
EIS but Is available at Lewistown, Sippery Ann, Jordan, and Fort 
Peck headquarters. 

8. The "Affected Environment" section deals only with those resources 
which may be Impacted or may impact the alternatives. In general, 
air quality is not one of these at CMR. 

9. A refuge-wide fire management plan will be developed before wild- 
fire and/or prescribed fire is integrated into habitat management 
on CMR. Your suggestions have merit and will receive considera- 
tion. 

10. Ownership of mineral rights on CMR is fragmented between the COE, 
FWS , State of Montana, and private individuals. Some COE lands are 
withdrawn from mineral entry at this time. Development proposals 
on FWS lands will be considered by the Secreatry of the Interior 
and a determination made in accordance with refuge objectives and 
energy policies at that time. Executive Order 7509 addresses 
mineral exploitation; please see Appendix 4, page 159. 


1100 Missoula Avenue 
Helena, MT 59601 
November 22, 1980 


Wally Steucke, Area Manager 
U. S. Fish and Wildlife Service 
Federal Building, Room 3035 
316 N . 26th St. 

Billings, MT 59101 


Co: cm /g 


Dear Sin 

This comment responds to the draft environmental impact statement for the Russell 
Wildlife Refuge. Our interest is that the refuge be managed for the benefit of 
wildlife — that any livestock use reinforce this objective. This management should 
be accomplished by use of natural methods to the fullest extent possible. 


The Russell Refuge can demonstrate the value of wildlife refuges for other purposes, 
such as benefits from healthy watersheds and for public enjoyment. Control of 
livestock trespass is essential for this program. Roads should be kept to a minimum. 

We question the validity of three of the options i "A - no action" is not a benefit 
to wildlife habitat; "D - multiple-use" increases livestock use and develops ponds 
and fences to pull livestock into unused areas — probably now of primary value to 
wildlife. (The term "multiple-use" could easily encompass the other options in vary- 
ing degree); "S - no livestock" is not a viable option since it is not politically 
or socially acceptable. "A" and "D" circumvent the various legal requirements to 
make the refuge of primary benefit to wildlife. 

The EIS cites many Instances where cattle grazing and wildlife are in conflict, but 
is only general on the location and degree. It also notes that cattle can be grazed 
to provide some beneficial results for antelope and deer habitat. There is considera- 
ble literature backing up the conflicts, but the beneficial results of overgrazing are 
probably outweighed by soil erosion and detriment to most wildlife habitat. 


The EIS seldom gets into specifics. Unless this is done, intelligent comment is 
difficult. Examples of where the EIS should provide more information followi 


1. Acres and location of conflict between livestock grazing and ground nesting 
birds such as sharp tall grouse. 

2. Acres and location of conflict between cattle, deer and elk, particularly on 
big game winter range. 

3. Condition, location and acres of primary cattle range, particularly areas in 
fair and poor condition. 

4. Soil losses in tons/A attributable to overuse. 

5. Production of forage for cattle on primary ranges on lbe./A basis. 

Examples of the difficulty of piecing together scattered bits of information followi 


* 

I* 


From your description of the range conditions it appears that most of the livestock 
use falls in the "fair" classification of 7 % of the area, or on about 58,000 acres. 
AUMs of use on the Russell is given as 56,524 AUMs. Since a very large share of 
cattle use is on the fair condition range, the use approaches 1 AUM/acre. Unfortun- 
ately, no production or acreage figures are given for the primary range areas. On 
page 1?5 the average product ion/acre on given excellent ranges averages about 


Wally Steucke Page 2 November 22, 1980 


1200 lbs. /acre. On fair range, production would be no more than half or 600 lbs. /acre. 
If 30 to 4056 is proper use, then it takes not one acre but three to four acres per 
AUM. These figures are only applicable as averages because of the lack of informa- 
tion. They could indicate that your proposed reduction of use may be optimistic. 

Where use is heavy, cattle tend to browse more. This brings their use into conflicts 
with sharptail grouse and pheasants which use buffalo berry, chokecherry, and other 
brush for food and cover. Heavy use also reduces available browse for elk and deer 
in the winter. 

You do not indicate how you plan to handle the reductions. Reducing numbers, parti- 
cularly on seasonjftfifenges. will pull cattle off the steeper slopes and areas further 
from water but otherwise does not do much to lower concentrations nearer water. 

Reducing spring use (which may be planned but not shown) will provide much greater 
benefits than reductions in numbers of cattle. 

We generally support the CMR goals, wildlife and range objectives on pages 4, 5, and 
6. We applaud your proposal to introduce peregrine falcons, black footed ferrets, 
and the Rocky Mountain bighorn. 

In conclusion, we wish to emphasize that these public lands have been set aside for 
the benefit of wildlife. The goals of improving wildlife habitat on these rough lands 
are in harmony with protecting the land and water for the longrange public interest. 

However, we do not oppose reasonable grazing by livestock where this meets the primary 
wildlife objectives. 

At this time the F and W "Proposed Option B" substantially improves the position of 
wildlife on the refuge, with some allowance for livestock use. We support the F and W 
proposal "B." 

Sincerely, 

— ^ **jUsC*J 

Noel Rosetta, Resource Consultant 
Upper Missouri Croup Sierra Club 




Response to the Sierra Club, Upper Missouri Region 


1. The Information requested Is beyond the scope of this document. 

Much of the information is contained in refuge files which are 
available for your examination at the refuge headquarters in 
Lewistown, Montana. 

2. According to the Montana State Office of the Soil Conservation 
Service, no monitoring programs of this type have occurred on CMR, 
and thus, this type of data is unavailable. 

3. See response #1 above. 

4. AUM reductions are on an allotment-by-allotment basis, depending on 
the needs of wildlife in each allotment. In general, going to 
light grazing, as provided for in the Proposed Action, will result 
in light to moderate grazing in level areas near water. In steep 
terrain and away from water, there will be little, if any, live- 
stock grazing. Also, in general, turn-on dates for livestock will 
be later in the spring than at present. Livestock grazing in all 
habitats on the refuge will be governed by wildlife objectives; if 
the proposed level and type of grazing do not allow these objectives 
to be achieved, grazing will be modified. 


294 


Valley County Development Council 

Courthoun Annex, Room 2 
Pom OHIco Box 832 
Glasgow, Montana 69230 
Tal: (406) 228-9389 


November 26, 1980 


Erwin W. Steucke, Area Manager 
Fish & Wildlife Service 
Federal Building, Room 3085 
316 North 26th Street 
Billings, Montana 59101 

RE: Expansion on brief Oral Statement presented at the October 30, 1980 

Public Hearing held in Glasgow, MT. by the U.S. Fish and Wildlife 
Service addressing the Draft Environmental Impact Statement (DEIS) 
on future management of the Charles M. Russell National Wildlife 
Refuge (CMR) . 

ORGANIZATION PRESENTING STATEMENT 

The Valley County Development Council (VCDC) which has been designated by the 
County Commissioners as the 'Overall Economic Development Program Committee' 
for Valley County since 1968. This organization has a county-wide coordinating 
and planning position in association with the various organizations, special 
committees, cities, towns, county, state, and federal departments and agencies. 

A considerable portion of this is directed to our natural and renewable resources 
as a priority subject. Statement presentation by Manson H. Bailey, Jr., Executive 
Director, by approval of the Board. 

STATEMENT 

The subject of this Hearing i9 of great importance to all people, most especially 
those of the six counties wherein the CMR is located and eastern Montana as a 
whole. The manner of its management has and will have a great impact to the 
many interests associated with it. Of the four hearing designations this is the 
nearest and most familiar to the subject. It is our hope that the "voice of the 
land" be heard by those here and associated in the coordination of the final 
management draft. 

The Draft demonstrates that a tremendous amount of work has been done in research 
and assembling the DEIS. It is presented to the public to voice certain choices 
and as in any book review , to meet the critics . These remarks will be tempered 
by the writer's personal memory and association with the CMR since the first 
Executive Order establishing the Fort Peck Game Range in 1936. More closely 
associated the past 30 years in many capacities which include being a member of 
the County Soil Conservation District Board, 1951-57, Member of the Montana Fish 
and Game Commission 1952-56, Member of the State Legislature in the 1960 's, 
presently serving as a member of the Montana State Historical Society Board of 
Trustees, and in this present position of development director since 1969, Member 
of the third generation of pioneer Valley County settlers. 

Keep Valley County Growing 


Erwin W. Steucke, Area Manager 
Page 2 

November 26, 1980 


HISTORY 

Most planning documents feature a history relative to the subject being addressed, 
which has a considerable bearing on future goals. In reviewing the document, one 
gets the impression that conditions on the CMR have not been beneficial to wild- 
life. Yet, in actuality, history does not bear this out nor does the range site 
condition survey of the DEIS. May we present some background history which may 
be beneficial to those not of this area and those in planning of a final document. 

° Authorization : President Franklin D. Roosevelt's Executive Order establishing 

the Fort Peck Game Range, December 14, 1936, (DEIS pages 157-158), mentions reserve 
of forage for 2 species of wildlife, sharp-tailed grouse and antelope (this is 
about all there wa9 at that time) , and mentioning further availability of forage 
for livestock as to be compatible with wildlife management. It was jointly managed 
by the Fish and Wildlife Service (F & W) and the Bureau of Land Management (BLM) 
for some 40 years with very creditable advances in wildlife species and numbers. 

o Conditions : It must be remembered that in 1936, it was in the middle of the 

great drought of the west. The only deer in the area were some white-tail along 
the Missouri River which was just starting to form a lake back of the new Fort 
Peck Dam under construction. The private landholders of these good valley lands 
in the six counties were beginning to move off of the land to be flooded. 

° Land Management : 1934 , passage of the Bankhead-James Taylor Grazing Act 

regarding management of public lands and a return to the states' of a portion 
of the fees collected in their use. 1935 , Montana Legislature authorized the 
Montana Grass Conservation Commission and formation of Cooperative State Grazing 
Districts under the guidelines of the Taylor Grazing Act. These Districts, of 
local citizen boards, brought about the first semblance of management of the 
public lands (building of dams with WPA labor and horses) including the Fort 
Peck Game Range. 1937 , District I BLM was established in Malta, very few personnel 
but funds for development of water retention structures was a great assist in the 
spreading of the grazing pattern for domestic and wildlife and range improvement. 
Qualifying grazing permits to those operators who could show resources to care for 
their stock during the period of the year they were not grazing public land. 

During the 1940's the horses running wild on public lands were taken off, leaving 
greater amounts of forage for other uses and range improvement. 1940's , the start 
t ^ e Conservation Movement on the land by the operators, private and public. 

Soil Conservation Districts were formed and qualifying for engineering and tech- 
nical supervision by the Soil Conservation Service (SCS). Grazing Districts were 
also eligible for this service. This, along with participating funds through the 
Agriculture Adjustment Act (AAA), a whole new pattern of land use was developing 
and extended on to rest-rotation systems of land use and improvement. 1969 , 
County-Wide Soil Survey , this office initiated and working through the local Soil 
Conservation District and State SCS Office, obtained a project to accomplish such 
a survey. All land holding agencies and private land holders helped finance the 
project, with the major funding provided by SCS as well as the technology. It is 
a valuable tool in dealing with land management, and used by the CMR planning 
team in knowing what the soils are and what vegetation they will support. All of 
these factors have brought about great changes for good, including the ability to 
better sustain wildlife and domestic livestock both on and off the CMR. 


Erwin W. Steucke, Area Manager 
Page 3 

November 26, 1980 


o Cooperative Advancement : It was through a great amount of effort and cooperation 

on the part of many entities and individuals that the resources were improved and 
the wildlife returned in great abundance to the prairies. Elk - In the 1940 's and 
1950 's was a period of large Sportsman Clubs in Eastern Montana. Through a coopera- 
tive move, these clubs pooled resources to finance the introduction of Elk on the 
Game Range in south Valley and Phillips Counties, from Yellowstone Park in the bad 
winter' of 1951-52. Submitted as EXHIBIT I is a copy of a recent news story on the 
elk of the CMR. The ranchers of the area agreed to the introduction which has been 
most successful, but the numbers far exceed what was agreed upon at that time. It 
should be noted that they cover great distances in their movement on and off the 
CMR and on Federal, State, and Private lands. It was ranch stock trucks which were 
furnished in transporting the elk here with stockmen doing the driving, as they 
were accustomed to handling stock. There were considerable hardships encountered. 
Examples : Three trucks were traveling together at night in stormy weather trying 

to make the trip as soon as possible. One truck became separated and in bad condi- 
tions slipped off the road and partially tipped over. The two men were able to 
hold the lek in the truck, they searched out and obtained another truck. These 
two big cowboys hand wrestled one elk at a time from one truck to the other and 
continued on. These were Frank Lock and Jack Rosenwald. It took considerable 
repair on the first truck. (Later both of these men dealt for ranches with 
grazing extending onto the CMR, one in Phillips County and one in McCone County.) 
Another truck with Bob O' Brian was traveling on a County road In Phillips County 
south of Saco, where the engine broke down. It was not far from the destination, 
so the elk were unloaded and guided by airplane into the "Larb Hills." Some 
trucking bills were never paid. 

Fish and Wildlife Management Headquarters were established at Fort Peck. The first 
"pinioned" Canadian Geese brood flock was established at Bowdoin refuge in 1951, 
which established the local population in this area, later one was established at 
the western portion of the CMR at U L Bend area in 1955. 

Forage allotted to domestic livestock on the CMR was reduced. Mule Deer and 
antelope reached explosive numbers throughout the prairie lands of northeast 
Montana not just the CMR. It must be noted that 1080 used in coyote control 
had a considerable influence in this Increase. 

Fort Peck Interagency Committee : One of the greater cooperative influences was 

the establishment of this committee in 1955. See EXHIBIT II . This was made up 
of all the different agencies and interests both public and private associated 
with the entire Fort Peck Project. Fish and Wildlife Service , Corps of Engineers 
Montana Fish and Game Department . State Parks . Counties , State Highway Department . 
Sportsman , Grazing Districts . Ranchers , Fort Peck Forward , and other private interests. 
This group met twice annually at different cities in the counties around the project. 

It has no official authority but through cooperative influences and dedication, great 
advancements have occurred. 

Rancher cooperation throughout all of this advancement has been good, even in the 
light of the damages they sustain in crop damage by wildlife and the numbers of 
recreationists they accomodate on private lands as well as public lands. 


Erwin W. Steucke, Area Manager 
Page 4 

November 26, 1980 


DEIS ALTERNATIVES PRESENTED 

The DEIS presents 5 Alternative Management Proposals. It is hoped that through 
public input that the definitions and qualifying features can be changed to come 
up with a more acceptable plan than is featured in any one of the choices presented. 

1. Alternative A - No Action : Of the choices presented, this organization and the 

majority of the local populace favor this proposal . However, as written and the 
connotation of title, NO ACTION, Indicates a degradation of wildlife management 
which has not been the case. It is evident from the abundance of wildlife pro- 
ductivity of the CMR over the years and the present forage condition, that it 
was not by happenstance or non-wildlife management goals that this has occurred. 

It has been through a broad cooperative effort, prominent among the list are the 
people of the land, the ranchers involved. 

(Some personal thoughts garnered over the years is that another resource, besides 
wildlife or natural resources, which must be considered is the human resource . 

The management of natural and renewable resources can best be accomplished to 
the extent of management of the human resource. The human resource in America 
is best managed by cooperation and education . In this case not the steadfast 
idealists, or those pressures from afar who know little of the situation. My 
old artillery Captain used to say "Everything depends on the situation and the 
terrain." It Is my personal thought that a higher hill needs to be climbed in 
the writing of the final EIS for a broader view of the situation.) 

o Prairie Dog : On page 7 of the DEIS (No Action) and in all the proposals, the 
prairie dog is mentioned in various rolls. Page 7 "No prairie dog or other small 
mammal control would occur on the refuge except for human health and safety purposes." 
This Is one of the most contested of all species on the CMR. The people of this 
area are taught and practice good conservation methods. To review the present 
acreage inhabited and proposed expansion is incomprehensible to the people. The 
devastation of the land and forage where they locate is so complete in resource 
spoilage that It far over-shadows any of the benefits mentioned. This also places 
a cloud over the management techniques of the whole refuge. 

o Livestock AUMs - It appears that under this proposal there would also be a large 
cut back in "livestock levels of approximately 33 percent below current federal 
AUM levels on the refuge" (page 10). Over these many years there have been grazing 
adjustments, changes of grazing systems and adapting through a greater knowledge of 
our resources on (and off) the CMR, to the benefit of the basic resources, which in 
turn has made the CMR one of the most productive of refuges in wildlife. At the 
same time continuing to be a part of the economic base through ranching. Cattle 
can be a benefit in reaching optimum vegetation conditions for wildlife. This 
should be done in a planned, long range program with the participation of the 
rancher and other interests. It will afford a continuity of operation for all and 
not on 'on again off again' program of uncertainty, at the sole direction of CMR 
management, which changes often. Although good individuals, most are not familiar 
with the ways of the prairie and its people (human resource) . It was good to note 
the range site survey of individual livestock operators on the CMR, pages 181-183, 
overage out 90X good to excellent condition. 


285 


Erwin W. Steucke, Area Manager 
Page 5 

November 26, 1980 


2. Alternative B (Proposed Action) - This seems to be the favored one by those 
presenting the DEIS. There are too many things to cover here to be compatible 
with good management. 

o Coyote - Is the refuge just for wildlife alone or is man to have a roll in the 
harvest of excess. 

o Rocky Mountain Big Horn & Bison - There needs to be more study and explanation 
before this consideration. The Big Horn has been tried, unsuccessfully as a 
sideline. See EXHIBIT III . (This was while I was a member of the Montana Fish 
and Game Commission. 

o Fencing - This should be to a very minimum and then in relation to rest rotation 
pasturing plans or systems. 

The other alternatives do not have a place. The description of multiple use is 
different than we know it and is self-disqualifying under this description. 

There is a need for a resubmittal of a DEIS for consideration. 


Response to Valley County Development Council 


1. We appreciate the background history provided in your letter. It 
helps to gain an understanding of the present situation and view- 
points of the refuge. 

2. Harvest through hunting is provided for in all the alternatives for 
game species. 


The 

Wilderness 107 West Lawrence, Helena, Montana 59601 (406) 443-7350 

. Mail to: P.O. Box 1184 

Society 

J December 3, 1980 


Mr. Wally Stuecke, Area Manager 
U. S. Fish and Wildlife Service 
Federal Building, Room 3035 
316 N. 26th Street 
Billings, Montana 59101 

Dear Mr. Steucke: 

Please accept this letter as official cccment from The Wilderness Society on the 
Draft Master Plan for the C. M. Russell National Wildlife Refuge. I first want 
to say that I am personally familiar with the CMR. You may recall last October 
when myself and other conservationists participated in a Fish and Wildlife Service 
sponsored tour of the west half of the Refuge. We took this tour with then newly 
appointed CMR Refuge Manager, Ralph Fries. We toured the Refuge fran the air, 
on the ground and by foot. We saw a wide variety of wildlife species and an 
incredible diversity of natural habitats ranging fran the riparian zone to the 
rougher break country up to the flat bench land on both sides of Fort Peck Reser- 
voir. Without question the CMR National Wildlife Refuge is a unique national 
resource of imnense proportions. It is simply unequaled any where else in the 
world. It stretches for 125 miles through sane of the finest wildlife habitat 
in the lower 48. 

Of key significance is the fact that the CMR is a National Wildlife Refuge. The 
CMR is a wildlife refuge first and foremost despite the fact that many people 
seen to conveniently overlook this important fact. 

The National Environmental Policy Act requires that Federal Environmental State- 
ments provide to the public a reasonable range of alternatives. However, the 
CMR Master Plan fails to do this. Other than the preferred alternative, the 
Master Plan EIS includes four other possibilities, all of which are basically 
nonaltematives. The no-action alternative is not a real choice in that most 
everyone recognizes the need for affirmative management to protect the wildlife 
resources on the CMR. The so-called multiple use alternative is not even .a. legal 
optic® for a National Wildlife Refuge. The no grazing alternative is, of course, 
a political impossibility . Further, we would oppose a ccnplete elimination of 
grazing on the CMR because we believe that well managed grazing and protection 
of wildlife resources are mutually beneficial and caipatible. 

Finally, the intensive wildlife alternative involves far too much heavy handed 
manipulation of the natural environment including plowing, spraying and dam 
building all at prohibitive cost with serious damage to the environment, so that 
this too is an unreasonable option. 


"In wildness is the preservation of the world." - Thoreau 


Mr. Wally Stuecke 
December 3 , 1980 
page 2 


The Wilderness Society generally supports the basic thrust of the preferred 
alternative calling for grazing reductions that would average 33 percent. 
However, we cannot tell from reading the plan how these precise cuts were 
derived. Therefore, we have no basis of knowing whether the reductions are 
too large or too small. I discussed this with Ralph Fries at a meeting in Miles 
City on October 15th and he replied that the Fish and Wildlife Service has anple 
documentation to back up the proposed grazing reductions. I certainly hope so, 
because we are not given this important information in the Master Plan. 

We recognize that livestock is by far the most significant issue dealt with in 
the Master Plan. The statement itself makes it abundantly clear that conditions 
for wildlife on the CMR are far from optimal because of grazing-induced resource 
problems. 


As eluded to above, the Master Plan tends to direct the reader toward the preferred 
alternative by presenting other alternatives which are simply unrealistic. The 
Master Plan violates the NEPA requirement for presentation of the full range of 
viable alternatives. Therefore, The Wilderness Society strongly urges that the 
Fish and Wildlife Service develop another alternative. One that considers live- 
stock grazing as a management tool that would be used on a prescriptive basis to 
achieve appropriate habitat conditions for wildlife. Grazing would have to be 
applied carefully and very selectively if it is to be sucessfully employed to 
improve wildlife habitat. This alternative must include site-specific objectives 
for each habitat type based on specifically identified wildlife needs. Grazing 
would be used as one tool to modify vegetative habitat. The season of use, 
stocking rates, levels of utilization and other grazing parameters should then 
be tailored to meet the objectives of each habitat type. This approach would avoid 
the problem of grazing being spread indiscriminately across different habitat 
types without careful selectivity. 


* 


When Ralph and I toured the CMI last year, he and I engaged in many hours of 
philosophical discussion about natural management versus manipulation. I want 
to reanplify my strong support for natural systems management on the CMR. 
Unfortunately, the preferred alternative in the CMR Master Plan proposes ripping 
as much as 10,000 acres of the Refuge in order to supposedly improve vegetative 
productivity for wildlife. We feel strongly that this action would conflict 
directly with the mission of the CMR which is to provide optimal wildlife pop- 
ulations in a generally natural setting. I feel very strongly that wildlife 
does not need plowing, spraying and fences to survive. We urge that the Fish 
and Wildlife Service manage the CMR for it's natural values allowing natural 
processes to operate for the benefit of wildlife and that the Service make every 
effort over time to remove human intrusions to the max brum extent possible. 

Curing our tour last year, we observed areas near Slippery Ann where farming has 
taken place along the Missouri River Bottom. We strongly support the Fish and 
Wildlife Service Plan to phase out fanning operations along the Missouri River 
Bottom as we believe that this will benefit wildlife and allow a more natural 
form of management for indigenous wildlife species. 


The Fish and Wildlife Service is to be commended for it’s proposal to reintroduce 
Bighorn Sheep, Blackfooted Ferret, Swift Foxes and Perigrine Falcons. This is 
sane of the most exciting wildlife news received in Montana in a long time and I 


286 


Mr. Wally Stuecke 
December 3, 1980 
page 3 


want you to know of our complete, enthusiastic, wholehearted support for the j 

plans to reintroduce these species. 

I note that the Fish and Wildlife Service reccnmends that cabins it es be retained 
on the Refuge. Frcm a strict conservation standpoint . recreational homesites on a j 
National Wildlife Refuge are inappropriate. Tbey may even conflict directly with 
wildlife, although . I actnit that this would be hard to prove. On the other hand, 

The Wilderness Society appreciates the importance of this form of recreation in the 
Glasgow/Fort Peck area as well as the scarcity of comparable recreational oppor- \ 
t uni ties in northeastern Montana. Although we might prefer that these cabinsites | 
be phased out, we do not make this recorrmendation . We do ask , however, that no 
new cabinsites be permitted on the Refuge and that the line be held where it is, 
insofar as recreational cabinsites are concerned. ; 

Predator control has long been an extremely controversial issue cm the Refuge. I 
recall only too well the controversy concerning plans to shoot coyotes on the 
ice during the winter time in years past. I note that the Fish and Wildlife 
Service has basically avoided the issue of predator control in the Management Plan. 

I believe that since we are dealing with a National Wildlife Refuge, predator 
control should take place in a very selective manner, in cases such as when f 

endangered wildlife species need protection. In either event, predators should 
not be routinely killed simply to protect livestock but should rather be care- 
fully controlled based on the overriding needs of wildlife. 

In closing, I would like to cite the final recommendations on the management of 
the National Wildlife Refuge System, dated 1970. In this policy, the Fish and 
Wildlife Service states that grazing is permitted on National Wildlife Refuges j 

as long as it's "employed for the benefit of and is not harmful to wildlife and 
wildlife habitat". I believe that this is an excellent farsighted policy and 
we commend the Fish and Wildlife Service for adopting it. We urge the Service 
to adhere to it insofar as the CMR Management Plan is concerned. j 

Completion of this Management Plan is only the first step toward a long process j 

of proper planning and protection of the publicallv owned resources of the CMR. 

The implementation of this plan will require sensitivity to the needs and concerns j 
of the local, state and national constituencies as well as a true sensitivity to 
the needs of wildlife. This will require a careful balancing process in the years 
to come. The Wilderness Society stands ready in every way possible to assist the j 
Fish and Wildlife Service to implement a viable CMR Master Plan. 

I have appreciated this opportunity to review the draft plan and I look forward 
to receiving the final. Please let me know if we can be of further assistance. 

^ Si ncerely^. 

Bill Cunningham A 
Regional Repres^gxat ive 


cc: Governor Elect Ted Schwinden 

Senator John Melcher 
Senator Max Baucus 
Representative Ron Marlenee 


Response to the Wilderness Society 

1. Please see responses to Defenders of Wildlife. 



Response to Wolf Point Chamber of Commerce and Agriculture 


1. The refuge was studied for wilderness suitability in 1974, as 
directed by the Wilderness Act of 1964. The result of this in- 
vestigation is now before Congress in the form of a proposal for 
wilderness designation of 161,460 acres contained in 15 parcels. 
Thus, the wilderness designation decision will be made by Congress 
sometime in the future, after it considers the 1974 study. The 
DEIS has no bearing on the wilderness designation. 

Neither the 1974 wilderness study nor the Proposed Action in the 
DEIS contain any proposal for a high fence around the refuge bound- 
ary or a proposal to eliminate the cabins or recreational areas 
within the refuge. 


287 


COMMENTS ON THE MANAGEMENT OF 
CHARLES M. RUSSELL NATIONAL WILDLIFE REFUGE 
DRAFT ENVIRONMENTAL IMPACT STATEMENT 

by George B. Chaffee, Resource Consultant 
po awuj I h-r- 

The following comments are submitted in response to certain 
aspects of the CMR-EIS as they pertain to alternative actions. 
After reviewing each of the proposed actions end in view of the 
CMR goals and objectives, it seems apparent this document is 
ambiguous relative to tangible approches in achieving wildlife 
betterment by natural management and manipulation of vegetation 
within the various ecosystems in the CMR Refuge. 

This evaluation of the ERS is addressed primarily to the 

following components mentioned in the CMR draft report. These 

include the following: 

Range Objectives, 

Habitat Management, 

Endangered or Unique Species Introduction, 

Forage Allocation, and 

Natural Management vs. Manipulation. 

Range Objectives 

The 1979 contract range survey clearly illustrates that a 
vast majority (92%) of the rangeland in the CMR is in Good to 
Excellent condition. It is well documented that wildlife forage 
and habitat benefit from good to excellent range condition that 
was achieved by management (proper use, deferred rotation and/or 
rest-rotation). Areas in less than satisfactory condition need 
to be under prescribed treatment based on the physiological 
requirements of the key forage plants (herbaceous and browse). 


2 

Under Alternative B (Proposed Action) the proposal to reduce 
grazing 33% iby 1985 and then implement by seasonal or continuous 
grazing at light stocking levels is counter productive in 
achieving habitat improvement and forage production. The intensity 
of use on unsatisfactory ranges would only differ by degree under 
continous or light use. Intensive grazing systems, such as 
rest or deferred rotation grazing, could achieve the goal of 
habitat improvement and increased forage production. Mapping 
of unsuitable range sites with severe soil hazards and limitations 
and certain sensitive river bottom sites (river wash and beach 
sands) is a means of adjusting AUMs to wildlife and domestic 
livestock. 

With a majority of the CMR refuge in good to excellent 
condition, the FWS is in an ideal position to achieve habitat 
improvement and forage production increases in a reasonable time 
frame by intensive graeing system implementation. 

The proposed action (Alternative B) is predicated upon 
initial livestock reduction and habitat improvement through cultural 
practices (i.e., burning, ripping, planting, etc.). This proposal 
is ecologically unsound without first monitoring an allotment area 
for several years under a prescribed grazing system in order to 
more accurately determine the suitable cultural tool (burn, spray, 
or reseed) to achieve the wildlife habitat goal. 

Light stocking and/or continous grazing as a prescription 
for range and habitat improvement is not the answer. Primary 
use (or key areas) will still endure overuse under this proposal. 


3 

Later season or winter grazing use can achieve improvement, but 
may not encourage the succession of the desired browse species. 
Livestock grazing under management with adherence to the 
physiological requirements of the key plant species (plant growth 
and regrowth) should be the vehicle upon which to achieve 
improved habitat condition and forage production. 

Habitat Management 

This aspect of achieving habitat improvement and increased 
forage production goals has merit, if intensive grazing systems 
are implemented with the required pasture fencing, water development, 
and a limited amount of prescribed burning and some ripping. 

Extensive boundary fencing would serve no useful purpose in 
achieving habitat betterment unless management boundaries of 
range site and condition serve as the fence lines. Moreover, 
ecosystem boundaries (refuge and outside areas) would be severed 
by boundary fencing resulting in cverconcentrations of wildlife 
and livestock use on fence lines, coulee bottoms or riparian 
areas. 

Ripping and planting are recognized as good management tools 
on limited areas and with fenced protection. River bottom areas 
and abandoned cultivated lands would benefit from these 
practices rather than to extensively rip and plant upland areas 
where grazing management can achieve the same goal at less risk to 
erosion and more economically obtainable. In planting, monoculture 
would displace native vegetative diversity which is essential for 
higher biotic potential. The success of planting deciduous shrubs 
in the severe climatic conditions of CMR is not documented as high. 


4 

Overall, a cooperative approach to habitat management is 
imperative between the P.'S, BLH, IIDFV&P, end state and private lands. 
Except for certain river and reservoir bottom lands, a majority of 
the ecosystems within CKR are portions of ecosystems extending 
to adjacent ownerships, '--/hen Fort Peck Reservoir was flooded 
in the 1940s the major river ecosystem was destroyed, which 
impacted ell wildlife species dependent upon the deciduous riparian 
and mesic herbaceous vegetation in sustaining biotic community 
life. Dependence on portions of the river not inundated by the 
reservoir is higher than ever today - this means a cooperative 
land use planning approach - NOT a mono-management and preservation 
approach. The conglomeration of rangeland, pastures, cropland, 
deciduous cover and conifer types now provide the food, cover 
end security for all wildlife end domestic livestock thriving 
within each ecosystem. 

Endangered or Unique Species Introduction 

This action listed under Alternative B as a tool to reinstate 
historical occurence of species such as bighorn sheep, buffalo, 
ferrets and fox is an experimental approach with a potentially 
low benefit. 

The failure of the Billy Creek bighorn sheep transplant tells 
the story. Why repeat the transplanting of wildlife species in 
light of several previous failures on the CMR? 

Conversely, transplant elk are now prolific and adapting 
well in their new environment in the CMR. They feed on private, 
state and BLM ranges and will continue to expand their use and 


288 


5 

occupation of other ownerships within similar seasonal ranges. 

How do we mitigate these impacts on areas outside the CMR? 

In short, this action should be considered only on a very 
limited scale, not as indicated in the proposed action. 

Once again Alternative A - No action is the best alternative 
for the benefit of existing and potential habitat for wildlife. 

Forage Allocation 

Proper use factors for domestic livestock and wildlife 
have been a subject of confusion and uncertainty in the CMR. 

On the basis of the 1979 range survey results there is no 
justification for a 33 % reduction in livestock grazing by 1985. 
Existing livestock numbers on ranges in good and excellent 
condition need not be reduced to provide more forage for wildlife, 
if proper use criteria are used. Those ranges in fair and poor 
condition need to be implemented with prescribed treatment at 
initial stocking rates at proper use levels on key forage species 
to sustain yearlong wildlife use. . Forage allocation then should 
be made on the basis of existing and potential forage production 
expected under intensive management. There is sufficient evidence 
of the success of rest-rotation grazing, for example in the 
Missouri Breaks region, to believe that domestic livestock should 
be maintained at capacities in line with actual use/proper use 
data on implemented pastures. 

Overall there is a lack of supportive data and information 
to advocate the Proposed Action (Alternative B) . There seems 
to be only one sound decision - No Action (Alternative A). 


Response to Mr. George B. Chaffee 


1. Range conditions and wildlife habitat are not the same and should 
not be used synonymously. Range condition measures such parameters 
as species composition and projection and does not address impor- 
tant wildlife habitat components such as residual cover, vegetative 
lnterspersion, and diversity, nor does it attach sufficient impor- 
tance to key wildlife shrub communities. 

Because habitat is recognized as the key to wildlife abundance, 
this document emphasizes habitat quality and quantity. 

2. There are presently six rest-rotation and two deferred grazing sys- 
tems in operation on CMR. None of these systems have been shown to 
be significantly better for wildlife abundance and diversity than 
light seasonal grazing with a favorable season of use. Furthermore, 
intensive systems are a much more expensive alternative and detract 
morp from naturalness than the type of grazing generally suggested 
in the Proposed Action. However, wildlife and habitat objectives 
will determine the type of grazing on a specific area. 

The FWS feels that to first set up intensive grazing systems, then 
monitor response to determine what needs to be manipulated, would 
be unnecessarily expensive and would place wildlife in a secondary 
role. This is contrary to the enabling legislation for the area 
and against the policies of the FWS. 

The FWS agrees with the statement that "adherence to the physiologi- 
cal requirements of the key plant species" is essential to manipu- 
late habitat. However, vegetative requirements and wildlife popu- 
lation objectives have to both be considered in refuge management. 
Intensive grazing systems rarely can be operated with these con- 
straints in mind. 

3. See responses #1 and 2 above. 


COMMENT ON THE C.M. RUSSELL DRAFT ENVIRONMENTAL IMPACT STATEMENT 
BY MARTIN R. CONNELL. D.V.M., FORT PECK ROUTE. GLASGOW, MONTANA 
OCTOBER 30, 1980 

OPENING COMMENT: 

I find the environmental impact statement totally inadequate in 
dealing with the economic changes that would occur in the local 
business community if any of the alternatives except "no action" 
were approved. It Is beyond my comprehension that an environmental 
Impact statement can neglect such an important area as the effect 
on the small communities. Our last census shows that the small 
communities are already an endangered species. It was my under- 
standing that the CMR was to protect endangered species. 

All citizens of the affected counties and the entire State of 
Montana should be aware of this proposal by the CMR. They have 
cleverly put in a "no action alternative", which is the carrot 
on the end of the stick. There is no serious consideration of 
"No Action". 

I submit that this EIS Is not a format of alternatives but a 
Stepped Down Livestock & Recreation Reduction Plan that when 
Instituted will totally eliminate grazing, hunting, recreation, 
and cabin sites on the lake. 

This country has an energy shortage and every available resource 
must be used to stop our energy dependence upon the Arab world, 
yet, under this plan it would be Impossible to tap any of the 
energy sources that lie within the range. This statement says to 

- 1 - 


me that we want to live in the 1980's and 1 990 ' s like we did in 
the 1800's but we still want a flush toilet in the house. I feel 
any proposal should not stop exploration for valuable minerals. 

I realize that legislation may be necessary to make this change. 


REVIEW OF THE REPORT: 


I would like to dwell on some of the highlights that I found in 
reviewing this report. 

Page IX - The summary states: "No threatened species of animals 
are known to occur on the refuge. Endangered wildlife species 
Include peregrine falcons, bald eagles and possibly black-footed 
ferrets. Wildlife habitat on the refuge Is only in fair 
condition". I have consulted biologists and range specialists 
regarding this situation, and I am told that there is serious 
doubt that removal of cattle from the CMR would increase the 
quality of the wildlife habitat. Further discussions revealed 
that If there are any black- footed ferrets they have been brought 
In by the Fish & Wildlife. The bald eagle and peregrine falcon 
populations would not Increase If the CMR left the range alone. 

The only way that their numbers would increase is if the CMR 
people brought more In. The report further states on this page 
that "Grazing, and haying activities on the refuge, although limited, 
contribute to the economy". Is It not important in Eastern Montana 
to have contribution to the economy? 

Page X - The sunmary states, under Proposed Action Alternative, 
"Significant management actions would Include reduction in livestock 
grazing as well as changing existing seasons of use and modifying 
existing grazing^sys terns to benefit wildlife". I do not know how 


2 


289 


naive the managers of the CMR range are regarding Eastern Montana 
cattle operations; but one must realize that the grazing season in this 



the CMR. 

Paqe XI - "Spawning habitat for fish would be developed on the 


area is limited. Even a bureaucrat would have a hard time planning 

3 



reservoir". Talking with experts on the problans of spawning 
fish in Fort Peck Reservoir, they state that the biggest problan 

a different grazing season dealing with the logistics of our winters 

and weather. 



to spawning is the fluctuation In the level of the Fort Peck Lake. 

7 

"Farming along the Missouri River would be phased out but some lure 



Does that mean that the CMR is going to take over control from the 


crop farming could be implemented to decrease elk deprivation on 



Corps of Engineers on the water level? They hope to spawn Northern 


private lands". In recent discussions at Montana State University 



Pike and forget the problems of floods with their water control plan. 


with individuals who have worked with the elk herd in Yellowstone 
Park and other areas, they state that it will be impossible to keep 
the elk off private land. 

4 


This EIS statement implies that there will be no control of fires. 

I can envision, as has happened in the past, that local ranchers will 
be charged with trespassing for trying to control a fire on CMR 


The EIS states, "Federal Livestock AUM's would eventually be reduced 



ground that threatens to burn their private land. They would lead 

8 

33 percent below present levels. Some inholdings would be acquired 



us to believe that they will stand and watch the fire burn until it 


and ownership of all lands within CMR would be ascertained." Does 



reaches the private land and then they will put It out. This sounds 


this mean that they are going to condemn private lands? What has 
happened to the right of an Individual in this country when the 
government can take away private lands? Something the CMR and government 
bureaucrats tend to forget is that generations ago many of these lands 
were settled by pioneers. They worked hard to develop the land and 
they have passed it down from generation to generation. Along came 

5 


good on paper; but obviously they have not fought many fires. 

They further state in this alternative that private cabins would be 
eliminated and areas returned to wildlife habitat. More primitive 
fishing access sites would be provided and they would replace some 
existing high and low density recreation areas. That means that the 

9 

Fort Peck Lake and flooded the best farm land in Eastern Montana. 



sites would be Inaccessible. 


These people were pushed up on the shore and then along came the CMR 



Under the "Multiple Use Alternative" it says "Wildlife values would 


and now threathens to push them out entirely. I bellve that this is 



be equal to livestock as would recreation". Let us not be naive ... 


wrong! 



the CMR would be the one determining what is equal not you and I. 


In a discussion with a member of the CMR staff he revealed that under 



I do not like the loose wording that says; "Livestock weould receive 


the "Proposed Action Alternative" they would control the hunting by 

6 


approximately one-half the allocated forage". That should be spelled 


controlling the access. They do not want any hunting premitted on 



out in advance. It also states under this alternative that "Private 


-3- 



cabins would remaind as they are", does that mean there would be no 
-4- 



improvements and that there would be no further cabins? 


Under "No Grazing Alternative" "All private and state inholdings 
would have to be acquired before elimination of livestock grazing 
could occur since most of these areas are unfenced and stocked by 
the the operators at carrying capacity levels". My questions is 
how do they plan to do this? The only way that I can see that they 
could obtain such land would be by condemnation. One thing they 
forget to say after stating that "All livestock grazing would be 
eliminated by the year 2000. The entire refuge boundary would be 
fenced where possible". By the year 2001 the economic chaos created 
in the out-lying areas would eventually eliminate man from the CMR. 


I feel that at this point that they should add a 6th alternative called 
"All Livestock Grazing and Recreation and No Wildlife or Bureaucrats". 
It would take legislation to eliminate the CMR. 


Page 1 - The EIS states "Many wildlife-livestock problems at the Charles 
M. Russell National Wildlife Refuge have resulted from conflicting 
management and legislation". The conflicting management was when the 
CMR was given authority over grazing and the conflicting legislation was 
Public Law making the Fish & Wildlife Service sole administrator of 
the Wildlife Refuge. Who has caused the problem? The Corps of Engineers 
hasn't caused the problem, nor has the hunter/fisherman, nor has the 
recreationist, nor has the rancher. It appears to me that all the 
problems have been caused by CMR attitudes and employees. 


Page 5 - Under "Wildlife Objectives" CMR proposes to introduce the 
endangered species. I believe that it must be made perfectly clear to 
everyone involved that by allowing the CMR to introduce endangered species 
to the game range we effectively cofmrit hari-kari ! The entire CMR range 


to 


-5- 


and surrounding area, state and BLM land, will immediately come 
.under the guidelines of the "Endangered Species Act". This would 
be disasterous to all forms of recreation, hunting, livestock grazing, 
and make the present CMR problems sound like a tea party. 

Page 12 - The statement that really tickles me Is on page 12 where 
they state "Coyote control to benefit other wildlife species would 
occur as a last resort". If they are going to let nature take the 
course then why don't they let nature control the coyotes. The rancher 
has been portrayed as a vicious villain for trying to control the 
coyote that kills his sheep and cattle. Now the nature boys tell 
us they can’t run a CMR wildlife refuge without controlling 
the coyotes. . .that's interesting. Will they get 10-80 to do it? 

Under " Forage Allocation" they state "Livestock grazing on CMR would 
be substantially reduced to improve habitat conditions for wildlife". 

At this point it Is my strong feeling that independent experts from all 
phases of livestock grazing, biology, and wildlife management need to 
be brought together to answer the question if improvement would occur. 

In visiting with three different individuals on the subject I have 
consistently received the same answer; the removal of livestock would 
In all likelihood do very little to improve the wildlife habitat for the 
entire range. This is especially true on the CMR since such a small part 
of the range Is used for cattle grazing, due to Inaccessible terrain, 
low rain fall, and soil types. 

Pages 14-16 - Throughout this report I find a consistant attempt to 
lure the hunter, historian, fisherman, and recreationist into a sense 
of well being by statements that say "All existing roads and trails 

- 6 - 


290 


Including those that have been closed would be evaluated to determine 


practiced veterinary medicine In Eastern Montana for 15 years and it 

those that should be improved, realigned or closed". The last hearing 


appears to me that the only problem that has ever occurred with these 

angered the hunter, historian, and recreationist causing them to side with 


relationships are continual harassment by the bureaucrats driving their 

the stockman. It Is my belief that now they are putting sugar lumps in 


vehicles all over the land, building fences, and trespassing on ranches. 

the package to lure them from the cattlemen's side so they will not 


Very few recreationists and hunters have violated fences and land of 

object to this program. They go on to state "An additional boat 


the farmer/rancher. Most hunting relationships in Eastern Montana are 

launching, camping, and fishing access site would be developed", "Wildlife 


excellent. If you don't believe me, go to the western part of the 

populations would be harvested", and "Qualified cultural structures and 


state and other states where lands are totally closed. When we had the 

sites would be offlcally designated". To concerned citizens, "Harvested" 



Air Base there was excessive hunting pressure that caused problems, but 

could mean taking animals and putting them in another game range; not 

n 


I believe beyond any shadow of doubt that the relationship between the 

necessarily hunting. 



hunter and the rancher will continue to improve without the government's 

These are things put into this EIS so that they will appeal to all of 


interference. 

the Easterner's who have long since destroyed much of their heritage. 


Paqe 30 - Says "These flqures indicate that reqional effects due to 


Page 21 - Under "Multiple Use" the openinq statement is "This alternative 


grazing changes on CMR would be insignificant under any of the 


would not be possible to implement unless Congressional action changed 


alternatives. Primarily, effects of grazing changes would be felt 


CMR from a national wildlife refuge to a multiple sue management area". 


by permittees who use refuge lands". This is nonsense. The economic 

13 

I believe that strong consideration should be given to legislative 


effects will be severe and especially to the related businesses in towns 

changes which would solve our problem. In dealing with the CMR 


and the people who depend on these cattle for a livelihood. They must 


people, I believe that is has become obvious to all that the best interests 


be like the ostrich with their head in the sand. They have no idea 


of Eastern Montana are not being considered by the CMR. 


what Is going on and I will not waste my time going through the many 
allied services and businesses that depend upon livestock grazing. 


Page 24 - Under "Alternative E (No Grazinq)" the intention is to 




eliminate all livestock, all hunting, all fishing, and all public access 

12 


Page 31 - They state that Franklin D. Roosevelt, under Executive Order 

and don't you believe for one moment that the CMR people will be 


number 7509, In 1936 started the Fort Peck Game Range. Since that time 

swayed form their ultimate goal. 



we have suffered extremely. I think it is time that this group band 



together and bring about a dissolution of the CMR range. 

Page 27 - They say "Private land closures to public use. already a 



problem in the area, could be expected to accelerate, further 


Page 44 - There is a conment that "Adjacent landowners' and qrazinq 

jeopardizing farmer/recreationist/state/federal relations". I have 
-7- 


permittees' attitudes are negative toward this expansion and poaching 

-Q- 


and Illegal shooting could limit further extension of their range' 1 . 

This statement is made regarding the elk. The CMR totally disregards 
the rights of the permittees and adjacent landowners. They introduce 
the elk, then increase the size of the herd and push it to the limit. 
What do they expect landowners to do? They work to put up crops only 
to see them destroyed by the elk. What would a comparable CMR man 
and his wife do if their secure dwelling within the city limits was 
threatened by neighbors putting sheep in their back yard and once the 
neighbors grass was gone the sheep headed over to the bureaucrats yard? 

Page 50 - It states "No endangered or threatened species of plants 
are known to occur on CMR". Why should any be introduced? If God 
had wanted it to be there surely in His infinite wisdom He would have 
seen that they were growing. 

Page 103 - It states "Elimination of livestock grazing from the refuge 
could financially ruin many small, family-owned ranching operations which 
depend primarily upon refuge lands. Those livestock operators 
suffering high negative impacts in Appendix 10 would orobably be 
forced out of business". I thought our constitution guaranteed every 
Individual the right to the fruits of his efforts. 

I seriously doubt the constitutionality of ap proposal that would 
financially destroy generations of family owned ranches. The CMR 
bureaucrats admit that destruction is their plan and the tax payer 
will pay the bill. 

It is the time for all In Eastern Montana to band together and fight 
a battle against the CMR to the bitter end. 


SUMMARY: 


The Draft Environmental Impact Satement prepared by the CMR staff 
is incomplete because of the omission of the economic effect on 
local comnunitles and businesses. 


b 


It is not a plan with five alternatives for action; but rather 
a plan to be Implemented in five phases with the ultimate goal 
being elimination of all livestock grazing, hunting, fishing, and 
recreation. This includes the condemnation of private and state 
lands within the game range and removal of all cabin sites. 




The CMR bureaucrats intend to accomplish this take over by the 
introduction of endangered species; thereby bringing the entire 
area under the Endangered Species Act. The statement admits that 

"many small family owned ranching operations would be 

financially ruined". 

SOLUTIONS: 

A unified approach by all affected parties banning together into a 
cohesive group to stop the CMR take-over plan. 


This group would be faced with Intense negotiations with the CMR 
people to reach an acceptable alternative. 


Simultaneously task forces will develop specific legislation to 
stop or eradicate the CMR. 

CHALLENGE TO THE CMR BUREAUCRATS 
I Predict: 

That If you persist In driving the 11 vestockman, hunters, 
fisherman, and recreationist from the game range; 

- 10 - 


291 


That if you condemn the private lands and drive generations 
of families from their homes; 

A rebellion of destruction of game and burning ui forage 
will ravage the land. Once the Eastern Montanan realizes 
that it is the politicians from the big cities that prevent 
him from determining his own destiny, the frustration and 
di spare will drive the landowner in a desperate last stand 
to rid his land of the "CMR Pestilence". 


Respectfully submitted. 


♦All comments and quotations are taken from the Draft Environmental 
Impact Statement by the CMR, dated August 1980. 


Response to Dr. Martin R. Connell j 

1 . 

The entire economic situation has been reevaluated, and the text 
has been revised appropriately. 

2. 

An extensive review of the wildlife habitat under REP (see Appendix 
2) indicated that grazing is probably the major limiting factor on 
wildlife habitat at CMR. 

3. 

Minor changes in season of use can frequently have major changes in ! 

livestock-wildlife competition. 

A. 

The FWS does not propose to keep elk off private land, but lure 
cropping is one of several alternatives being considered to alle- 
viate or minimize crop depredations on neighboring ranches in late 
summer. 

5. 

The policy of the FWS is to acquire only lands needed to reach the 
goals of the refuge. When these parcels are identified for acquisi- 
tion, a willing seller basis will be used. Although the FWS has 
the authority to acquire lands by condemnation under very special 
circumstances, this authority is seldom used and is not planned for 
CMR. 

6. 

The FWS has no intention of limiting access nor of limiting hunting 
on CMR. 

7. 

The FWS will cooperate with the Corps of Engineers and the Montana 
Department of Fish, Wildlife, and Parks so that Fort Peck Reservoir 
is managed in the best manner for the fishery resources that will 
comply with the primary mandates of the Fort Peck project. 

8. 

Wildfire will be managed and controlled in accordance with the | 

refuge fire management plan. 

9. 

The FWS does not propose the elimination of cabin sites. 

10. 

The Endangered Species Act does not preclude hunting, fishing, or 
any other form of recreation, nor does it preclude livestock 
grazing when these activities do not jeopardize the continued 
existence of any endangered species or threatened species or result 
in the destruction or adverse modification of their critical habi- 
tat (Endangered Species Act of 1973 as amended Sec. 7(a)). 

11. 

The FWS proposes hunting (i.e. harvesting) not transplanting. 

12. 

Alternative E does not indicate nor include the elimination of 
public access. 


13. Please see response 01 above. 

1A. The FWS does not Indicate nor plan to introduce any endangered or 
threatened plants to CMR. 

15. Please see response #1 above. 

16. Please reread the EIS; your comprehension of the document is in 
error. 



292 


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' Mr. Jeff Denton 


a. The FWS feels that approximately 545,000 acres of elk habitat 
are present on CMR. 

b. Backup material is beyond the scope of the document and is 
available in the files at the refuge headquarters in Lewis- 
town, Montana. 

c. Yes, this population level would reflect improved range con- 
dition levels by the year 2005. 

d. Closely associated grassland communities refers to those 
communities that are located adjacent to forested types. Many 
times these communities are intermingled on the refuge. The 
FWS agrees that not all elk habitat is included in these 
categories. Riparian woodland habitat is an important community 
for elk also. 

Many wildlife species inhabit CMR, and it is not feasible to estab- 
lish specific objectives in the text for each species. Please see 
goals 1 and 4. 

FWS experience has shown that bison management by the Federal 
government is both difficult and expensive; therefore, use of bison 
to manipulate vegetation was not selected for the Proposed Action. 

The FWS will work with any permittee desiring to replace livestock 
with bison. 

Bighorn sheep habitat on CMR is not well understood. Should big- 
horn sheep become established on CMR, suitable habitat types and 
population goals will be established in cooperation with the Mon- 
tana Department of Fish, Wildlife, and Parks. 

Predator control has been adequately addressed in two previous FWS 
EIS's: Mammalian Predator Damage Management for Livestock Production 

in the Western U.S., and Operation of the National Wildlife Refuge 
System. 


5503 N. Cannon 
Spokane, WA 99208 


Erwin W. Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Rm 3085 
Billings, Montana 59101 

Dear Mr. Steucke: 

Alternative B in the draft of Charles M. Russell range impact 
statement is the only feasible management alternative listed. 
My comments will pertain to the "Summary" and Alternative B. 

In the Summary 


Wildlife habitat conditions are stated as "only fair". The 
charts on pages 80, 88, 96 and 102 show habitat for sharptail 
grouse and waterfowl are the only species listed in fair. 

Habitat conditions for pronghorn. Elk and deer are listed as 
good. More sagebrush would be available for grouse if livestock 
were allowed to overgraze grasslands now listed in good and 
excellent condition- -ecologically. 

Private cabin leases are a negative to most wildlife species. 

AUM values are $10 to $15 per each on private rangeland in 
Washington State. The rate should be adjusted from present 
extremely low of $1.89 to somewhere near the market value. 

There is no evidence that a 33 percent cut in livestock numbers 
is needed. The range is 92 percent good and excellent condition. 

The fair and poor ranges are partially prairie dog and "homesteader" 
tillage caused, and these areas, particularly the silver sage 
covered flats, are very important to wintering deer and antelope, 
also grouse. 

I believe that climate is the most obvious reason for wildlife 
limitations--not cows! Hunting (both legal and illegal is 
undoubtedly inhibiting game types also. Perhaps no-hunting instead 
of reduced livestock would be more effective. The CMR is a 
Wildlife Refuge not a hunting reserve. 


2^3 


Alternative B 

It is quite obvious in this section that thorough coorindated plart- 
ning 4s needed with each agency responsible for land management, 
livestock permittees, sportsmen, nature lovers and others involved. 

A coordinated range resource management plan with its alternatives 
and long range objectives (also short range) spelled out. 

The group needs to understand the base range resource and that 
wildlife must be first in perspective of all users. Problems of 
wildlife must be pinpointed on the land with the coordinated 
planning group to gain everyone's understanding and support. 

The coordinated planning approach used with ranchers, state and 
federal agencies, sportsmen, timber industry people and others in 
the states of Montana, Washington and Oregon would be very helpful. 
Conservation Districts serve as a catalyst for this planning effort. 
Soil Conservation Service in Bozeman, Montana, Spokane, Washington, 
or Portland, Oregon will gladly give you more information on coordin- 
ated resource planning and about its results. 

Burning native rangeland to improve stands of sagebrush is not suc- 
cessful. Burning will kill big sagebrush. Rabbitbrushes usually 
increase following a fire. Burning is dangerous. I personally lost 
one fire by whirlwinds-- I have known of rabbits spreading fires out- 
side the area to be burned. Burning takes land cover all off for a 
few years. This cover is badly needed to hold snow from blowing and 
protect soil from eroding. Some burning might be needed in dense 
timber areas but I doubt the benefits will exceed damages. 

There are other minor contradictory statements and lack of clarity 
which a good editing will correct. 

Roads and fences are costly to maintain and are negative to wildlife. 
These should be kept to a minimum. They can be replaced to some 
extent by more use of saddle horses, boats, barges and aircraft. 

Thanks for the opportunity to comment. 

Sincerely yours, 

Claude C. Dillon 
Range Consultant 

P.S. I made a statement at the Missoula meeting you may want to review. 

cc: Senator Max Baucus, Washington, D.C. 

Hank Fischer, Montana Rep., Missoula, Mont. 

Dennis Phillippi, SCS, Bozeman, Mont. 

Robert L. Ross, Bozeman, Mont. 

Peter V. Jackson, Harrison, Mont. 


Response to Mr. Claude C. Dillon 


1. The FWS manages CMR for diversity both in habitat and species. 

2. FWS believes the evidence is overwhelming throughout the EIS that 
there is a need to reduce livestock AUMs to improve wildlife habi- 
tat. 

3. Please see paragraph 5, page 11, for fire management in the Proposed 
Action. Past wildfires on CMR have resulted in excellent shrub 
communities on many sites; there is no reason to believe prescribed 
burns would not accomplish the same. Rubber rabbitbrush is heavily 
browsed by wildlife on CMR. 


1780 Arlington Drive 
Missoula, Montana 598 OI 
November 30, I 98 O 


Emin W . Steucke, Area Manager 
Fish and Wildlife Service 
Federal Building, Boos 3085 
Billings , Montana 59101 

Dear Sir, 

We are responding to the draft environmental impact statement on the 
management of the Charles M. Bussell National Wildlife Refuge. We support 
the issuance of an impact statement and your efforts to do so. It will 
provide and does general and much needed direction for managing the uses 
of the resources on the refuge. 

In general, we favor Alternative B (Proposed Action). However, in the 
final draft we would like the following direction added to Alternative Bi 


1 - Stocking rates calculated for domestic livestock are consistent with 

wildlife objectives and will either improve or have no negative impacts 
on wildlife species or their habitat, 

2 - Direction should be provided to improve the cover-forage ratios for 

all wildlife species. 


3 - A pond development program should be initiated and sustained to 
provide water for wildlife in areas where water is limited and/or 
in short supply during critical periods. Cover and forage should be 
protected in the area immediately adjacent to these developments.